📁 Data Retention and Disposal Policy
Better Choices Education LLC
www.BetterChoicesEducation.com
1. Purpose
This Data Retention and Disposal Policy outlines how Better Choices Education LLC (“Company”) retains, archives, and securely disposes of personal, administrative, and student-related data collected through its platform and services (“Services”). This policy ensures compliance with applicable laws and contractual obligations, including Connecticut General Statutes §§ 10-234aa to 10-234dd and FERPA.
2. Scope
This policy applies to:
- All digital records containing personally identifiable information (PII)
- Student assignment data, access logs, timestamps, and module progress
- Administrative and support communications
- Audit and system access logs
- Backup and disaster recovery archives
3. Data Retention Periods
| Data Type | Retention Period |
|---|---|
| Student assignment records | 7 years from date of completion |
| Student login/activity logs | 2 years from date of activity |
| Support tickets & admin communications | 5 years from resolution |
| System audit/access logs | 3 years from date of log creation |
| Backup archives | 30 days (rotating encrypted backups) |
Note: Longer retention may apply where required by law or contractual agreement.
4. Data Disposal Procedures
When data reaches the end of its retention period, the Company will ensure it is permanently deleted or destroyed using industry-standard practices, including:
- Secure deletion of cloud-based records using AWS tools (S3 lifecycle policies, database sanitization)
- Cryptographic erasure for encrypted storage
- Purging of redundant files from disaster recovery systems
5. School-Initiated Deletion Requests
Upon written request by a contracting school or district:
- Student accounts and related data will be deactivated within 10 business days
- Complete deletion from production systems will occur within 30 business days
- Confirmation will be provided once deletion is finalized
6. Legal and Contractual Exceptions
Data may be retained beyond the standard periods when:
- Required to comply with applicable laws or regulations
- Retained for audit, litigation, or dispute resolution purposes
- Stored only in encrypted disaster recovery systems without active access
7. Roles and Responsibilities
- Data Protection Officer: Oversees compliance with retention and disposal policy
- System Administrators: Ensure proper configuration of backup, deletion, and archival tools
- School Administrators: May request access, correction, or deletion of data per policy
8. Policy Review
This policy will be reviewed annually or upon significant legal or operational changes. Updates will be communicated to contracting districts.
9. Contact
For questions regarding vendor data privacy obligations, contact:
Better Choices Education LLC – Vendor Compliance Team
📧 Email: legal@betterchoiceseducation.com
🌐 Website: www.BetterChoicesEducation.com