Data Retention Policy — EduRegie
Retention periods per data category. Principle: do not retain data longer than necessary for the operational purpose (absence and substitution handling) or a statutory retention obligation.
| Data category | Table | Retention period | Explanation |
|---|---|---|---|
| Active absence case | absence_cases, absence_events | Duration of the absence + 12 months after closure | Needed for possible follow-up checks, recurring patterns and accountability towards the school |
| Timetable impact and substitution | lesson_impacts, replacement_candidates, replacement_assignments | Linked to the associated absence case — same period | Operational history, no independent retention value after the case is closed |
| Telephone/email intake (raw reports) | phone_call_intakes, email_intakes | 12 months | Only needed for as long as traceability to the case may be relevant |
| Notifications (sending log) | notifications | 12 months | Evidence of timely communication, no substantive medical data |
| Daily/weekly statistics | statistics_daily | 36 months, thereafter retained anonymized for trend analysis | Aggregated figures, low privacy risk; longer retention is justified for management reporting across multiple school years |
| Audit log | audit_log | 24 months | Needed for accountability and incident investigation |
| Staff data (master data) | employees | For the duration of employment + 12 months | In line with the usual retention period for personnel files; the school remains the data owner here |
| Portal user accounts | users (+ Supabase Auth) | Until the school has an account deactivated, no later than 3 months after end of employment | Prevents unused, forgotten accounts with access |
Automation
SF 20 - EduRegie Privacy Retention is the designated workflow to enforce these periods automatically (periodic cleanup/anonymization). When delivering to a school, verify that this workflow is active and uses the periods from this table as a parameter — the exact implementation (hard deletion vs. anonymization) deserves a brief code review before the first production delivery.
Exceptions
Retention periods may be longer if:
- an ongoing legal dispute or investigation requires retention;
- the school itself applies a longer, documented retention period in accordance with its own archiving policy (for example based on the Selection List for archival records in education) — in that case the school's instruction prevails, in accordance with article 3 of the data processing agreement.
The periods mentioned are a reasonable proposed starting point from Elhoucine Automation, not a statutory norm — align them with the DPO of each school before production delivery.