Data Retention Policy

1. Purpose

This policy outlines how long trackME retains different types of data and the procedures for data deletion. This policy ensures compliance with Australian Privacy Principles and helps protect user privacy.

2. General Principles

• Data is retained only as long as necessary for educational purposes
• Users can delete their data at any time
• Automatic deletion occurs after specified retention periods
• Deleted data cannot be recovered

3. Retention Periods

4. Active Account Retention

4.1 Definition of Active

An account is considered active if:

• The user has logged in within the past 12 months, OR
• Data has been accessed or modified within the past 12 months

4.2 Active Account Data

All data for active accounts is retained indefinitely, including:

• Teacher account information
• Classes and student rosters
• Progress and assessment data
• Curriculum assignments

5. Inactive Account Deletion

5.1 Inactivity Detection

Accounts are flagged as inactive after 7 years without:

• Login activity
• Data access
• Data modification

5.2 Deletion Process

1. Notification (90 days before deletion):
   • Email sent to registered email address
   • In-app notification (if user logs in)
   • Information about data export options
2. Grace Period (90 days):
   • User can reactivate account by logging in
   • Data export available
   • Account remains accessible
3. Deletion:
   • All account data permanently deleted
   • All associated student data deleted
   • All progress records deleted
   • Cannot be recovered

6. Student Data Deletion

6.1 Immediate Deletion

Student data is immediately deleted when:

• Teacher manually deletes a student
• Teacher deletes a class (all students in that class)
• Teacher account is deleted

6.2 Cascading Deletion

When a student is deleted, the following data is also deleted:

• Student profile information
• All progress records (skills, knowledge)
• All assessment results
• All subject enrolments

7. School Account Deletion

7.1 School Deactivation

When a school account is deactivated:

• All school user accounts are notified
• Data export is made available
• 12-month retention period begins

7.2 Deletion Process

1. Notification sent 30 days before deletion
2. Final data export opportunity
3. All school data permanently deleted after 12 months

8. Audit Log Retention

Audit logs are retained for 7 years for:

• Compliance purposes
• Security investigations
• Legal requirements

After 7 years, audit logs are automatically deleted.

9. Data Export Before Deletion

Before any automatic deletion, users are provided with:

• Email notification with export instructions
• 90-day window to export data
• JSON export functionality
• Instructions for data backup

10. Manual Deletion

10.1 User-Initiated Deletion

Users can delete their data at any time through:

• Settings page → Data Management
• Individual student deletion
• Class deletion
• Account deletion

10.2 Immediate Effect

Manual deletions take effect immediately and cannot be undone.

11. Legal Holds

In certain circumstances, data deletion may be suspended:

• Ongoing legal proceedings
• Regulatory investigations
• Security incident investigations

Users will be notified if their data is subject to a legal hold.

12. Backup Data

Firebase maintains automated backups for disaster recovery on Melbourne, Australia servers. These backups:

• Are retained according to Firebase's policies
• May contain deleted data for a limited period
• Are not accessible for normal data recovery
• Remain within Australian jurisdiction

13. Contact

For questions about data retention or to request early deletion:

Simon Dass
Email: simon.dass.1996@gmail.com
VIT Registration: 615660