Subject Rights Retention Policy

  • Updated

When a subject rights request is received information must be collected in order to respond to the request. To maintain an auditable log of received requests and the responses they received much of that information is retained indefinitely. Collected information that may fall into the category of personal information however is subject to the following retention limits:

 

Information Collected Retention Limit
Requester Email 730 Days
Requester First Name 730 Days
Requester Last Name 730 Days
Requester Phone Number 730 Days
Requester Type (Customer, Employee, etc.) 730 Days
Request Description  730 Days
Requester Country of Residence 730 Days
Requester State/Province/Territory 730 Days
Requester PII – Custom Field  730 Days
Requester Sensitive PII – Custom Field 730 Days
Requester non-PII – Custom Field 730 Days
Requester Proof of Identity/Other Attachments 730 Days
Requester Secure Messaging Portal Attachments 730 Days
Subject Rights Manager Secure Messaging Portal Attachments 730 Days
Subject Rights Manager Request Attachments 730 Days
Subject Rights Manager Attachments on Action Items 730 Days
Subject Rights Assignee Attachments on Action Items 730 Days
Automated Data Store Summary Files on Action Items 730 Days
Automated Data Store Deletion Files on Action Items 730 Days
Reporting Dashboard Metrics  Indefinitely

 

Note: Data Processing and storage occur in AWS (Virginia, US). 

Upon completion or rejection of the request, Osano deletes the personal information from the customer’s admin application and only retains the assigned unique number used to identify the request within the Osano platform. Once the 730-day period is reached all PII is deleted from the platform.