Data Retention Policy

Last updated: 21 March 2026

This Data Retention Policy explains how long Jack Flanagan trading as Snapshot Education retains personal data and the principles we follow for data management.

1. Retention Principles

Data Minimisation

We only collect and retain personal data that is necessary for our educational service provision and legal compliance.

Time Limitation

Personal data is retained only for as long as required for the purposes it was collected, unless longer retention is legally required.

Purpose Limitation

Data is used only for the specific purposes outlined in our Privacy Policy and Data Processing Agreement.

2. Data Retention Schedule

Data Category	Retention Period	Legal Basis
User Account Information	Until account deletion	Service provision
Pupil Profiles & Assessments	7 years after last update	Educational record keeping (DfE guidance)
Special Educational Needs Data	7 years after pupil leaves school	Statutory educational requirements
Progress Tracking Data	7 years after completion	Educational assessment records
Parent/Guardian Contact Details	7 years after last interaction	Parental communication records
System Access Logs	12 months	Security and maintenance
Error Reports & Technical Logs	6 months	Service improvement
Analytics Data (anonymized)	26 months	Service development
Financial Records	7 years	Tax and accounting requirements
Complaint & Incident Records	7 years after resolution	Legal compliance

3. Special Category Data

Enhanced Protection

Special category data (including SEND information, health data, and ethnic origin) is subject to enhanced security measures and stricter retention controls.

Extended Retention

Some special category data may be retained longer where required for:

• Ongoing educational support and assessment
• Legal proceedings or regulatory requirements
• Public health or safety interests

4. Data Deletion Process

Automatic Deletion

Data is automatically deleted when retention periods expire through secure, irreversible deletion processes.

Manual Deletion Requests

Users can request immediate deletion of their data at any time, subject to legal and regulatory requirements.

Deletion Verification

We maintain deletion logs and can provide certificates of deletion upon request.

5. Legal and Regulatory Requirements

Extended Retention Circumstances

Data may be retained longer than standard periods when required by:

• Legal proceedings or anticipated litigation
• Regulatory investigations or inquiries
• Statutory educational record requirements
• Safeguarding or child protection concerns

Documented Decisions

All decisions to extend retention periods are documented with clear legal justification and reviewed periodically.

6. Data Archiving

Archive Storage

Data approaching deletion may be moved to secure archive storage with restricted access.

Archive Access

Archived data is only accessible for specific legal or regulatory purposes.

7. Your Rights

Right to Erasure

You can request deletion of your data, though we may need to retain certain information for legal compliance.

Right to Information

You can request information about how long we retain your data and why.

Right to Object

You can object to continued retention of your data in certain circumstances.

8. Multi-Academy Trusts and Local Authorities

Consistent Retention

MATs and LAs should apply consistent retention policies across all schools within their jurisdiction.

Data Transfer

When schools join or leave MATs, appropriate data transfer and deletion procedures are followed.

9. Policy Review

This retention policy is reviewed annually to ensure compliance with changing legal requirements and educational standards.

10. Contact Information

Data Protection Questions

Email: dpo@snapshoteducation.com

Response time: Within 30 days for standard inquiries

General Inquiries

Email: jack@snapshoteducation.co.uk

Address: [Insert Company Registered Address]