Data Retention Policy
Last Updated: January 11, 2026
Purpose
This Data Retention Policy establishes how long Elevate for Humanity retains different types of data, when and how data is deleted, and the legal and operational reasons for our retention schedules. We balance our need to maintain records with privacy principles and legal requirements.
Retention Principles
Our data retention practices are guided by:
- Legal Compliance: Meet federal and state record-keeping requirements
- Operational Need: Maintain data necessary for operations and services
- Privacy Protection: Delete data when no longer needed
- Security: Protect data throughout its lifecycle
- Transparency: Clear communication about retention practices
Student Records Retention
Academic Records
Permanent Retention:
- Official transcripts
- Degrees and certificates awarded
- Enrollment dates and programs completed
- Final grades and credits earned
7 Years After Last Enrollment:
- Course syllabi and materials
- Assignment submissions and grades
- Attendance records
- Progress reports and evaluations
- Disciplinary records
- Accommodation documentation
3 Years After Last Enrollment:
- Course discussion posts
- Peer interactions and feedback
- Non-graded assignments
- Draft work and notes
Admissions and Application Data
- Enrolled Students: Retained as part of student record (7 years after last enrollment)
- Accepted but Not Enrolled: 3 years from acceptance date
- Denied Applications: 2 years from denial date
- Incomplete Applications: 1 year from last activity
Financial Records Retention
Financial Data
7 Years (IRS Requirement):
- Tuition and fee payments
- Payment plans and agreements
- Refunds and adjustments
- Financial aid records
- Invoices and receipts
- 1098-T tax forms
3 Years:
- Payment method information (last 4 digits only)
- Transaction logs
- Billing correspondence
Employment and HR Records
Employee Records
- Personnel Files: 7 years after employment ends
- Payroll Records: 7 years (IRS requirement)
- I-9 Forms: 3 years after hire or 1 year after termination (whichever is later)
- Benefits Records: 6 years after plan year ends
- Applications (Not Hired): 1 year from application date
- Performance Reviews: Duration of employment + 3 years
Operational and Business Records
Business Records
- Contracts and Agreements: 7 years after expiration
- Corporate Records: Permanent
- Insurance Policies: Permanent
- Property Records: Permanent
- Audit Reports: 7 years
- Tax Returns: Permanent
- Meeting Minutes: Permanent
Technology and System Data
System Logs and Analytics
- Access Logs: 90 days
- Security Logs: 1 year
- System Backups: 30 days (rolling)
- Website Analytics: 26 months
- Email Logs: 90 days
- Error Logs: 90 days
User Account Data
- Active Accounts: Retained while account is active
- Inactive Accounts (Students): 7 years after last login
- Inactive Accounts (Applicants): 2 years after last login
- Deleted Accounts: 30 days in recovery, then permanently deleted
Communication Records
Email and Messages
- Student Communications: 7 years after last enrollment
- Administrative Email: 3 years
- Marketing Communications: Until unsubscribe + 30 days
- Support Tickets: 3 years after resolution
- Chat Logs: 1 year
Legal and Compliance Records
Legal Documents
- Litigation Files: Permanent (until statute of limitations expires + 7 years)
- Complaints and Investigations: 7 years after resolution
- Compliance Reports: 7 years
- Incident Reports: 7 years
- FERPA Disclosures: 5 years
Data Deletion Procedures
Secure Deletion Methods
When data reaches end of retention period:
- Digital Data: Securely overwritten using industry-standard methods
- Databases: Records permanently deleted and not recoverable
- Backups: Data removed from all backup systems
- Physical Records: Shredded using cross-cut shredders
- Electronic Media: Degaussed or physically destroyed
Deletion Schedule
Data deletion occurs:
- Automatically when retention period expires
- Quarterly review of data eligible for deletion
- Annual audit of retention compliance
- Upon user request (where legally permitted)
Exceptions to Retention Schedules
Legal Holds
Data may be retained beyond normal schedules when:
- Subject to litigation or investigation
- Required by court order or subpoena
- Part of ongoing audit or compliance review
- Needed for legal defense
Legal holds override normal deletion schedules until released by legal counsel.
Your Rights
Access and Deletion Requests
You have the right to:
- Request access to your personal data
- Request correction of inaccurate data
- Request deletion of data (subject to legal requirements)
- Request data portability
- Object to certain data processing
Note: Some data cannot be deleted due to legal requirements (e.g., transcripts, financial records during retention period).
Data Retention Compliance
Monitoring and Auditing
We ensure compliance through:
- Annual data retention audits
- Automated retention policy enforcement
- Staff training on retention requirements
- Regular policy reviews and updates
- Documentation of retention decisions
Contact Information
For questions about data retention or to request data access/deletion:
- Email: Contact Us
- Phone: (317) 314-3757
- Mail: Privacy Officer, Elevate for Humanity
- 8888 Keystone Crossing, Suite 1300
- Indianapolis, IN 46240
- Office Hours: Monday-Friday, 9:00 AM - 5:00 PM EST
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