Data Governance
Data Retention Policy
Last updated: July 2026
1. Purpose
This policy sets out how long ModelLaw Limited retains personal data and case data processed through the ETSS platform, in compliance with Article 5(1)(e) UK GDPR (storage limitation principle). Data is retained only for as long as necessary for the purpose for which it was collected.
2. Retention Schedule
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Account data (name, email, role) | Duration of account + 30 days | Contract |
| Case data (claims, issues, witnesses) | Duration of account + 6 years | Limitation Act 1980 (contract/tort: 6 years) |
| Documents (S3 uploads) | Duration of account + 1 year active, then archived 6 years | Contract + legal compliance |
| Audit logs | Duration of account + 6 years (anonymised on deletion) | Legitimate interest (dispute resolution) |
| Payment records | 7 years from transaction | HMRC requirements (s.12 TMA 1970) |
| Contact form messages | 2 years | Legitimate interest |
| Login/session data | 7 days (refresh tokens) | Contract (authentication) |
| Analytics data | 26 months (anonymised) | Legitimate interest |
| Email verification tokens | 24 hours | Contract |
| Password reset tokens | 1 hour | Contract |
3. Account Deletion
When a user deletes their account (via the in-app GDPR tools or by request):
- Account data is permanently deleted within 30 days
- All S3 documents are permanently deleted (all versions)
- Case data is permanently deleted
- Audit logs are anonymised (user ID, IP address, user agent removed) but retained for legal compliance
- Payment records retained for HMRC (7 years) — anonymised where possible
4. Subscription Cancellation (without deletion)
When a user cancels their subscription but does not delete their account:
- Data retained for 30 days (in case of resubscription)
- After 30 days with no resubscription: account downgraded to free tier
- Data retained under the free tier (1 case, limited features)
- User can request full deletion at any time
5. Automated Deletion
The following data is automatically deleted:
- S3 documents: archived to Glacier after 1 year, permanently deleted after 7 years
- Expired refresh tokens: purged weekly
- Expired verification tokens: purged daily
- Old database backups: rotated after 7-day retention
6. Your Rights
You can request deletion of your data at any time under Article 17 UK GDPR (right to erasure). Use the in-app deletion tool at Settings → Privacy → Delete Account, or email dpo@modellawoffice.co.uk.
7. Review
This policy is reviewed annually by the Data Protection Officer. Last review: July 2026. Next review: July 2027.