Data Retention and Disposal Policy

How long we keep personal data and how we dispose of it

Version: 1.0 · Last updated: 5 October 2026

1. About This Policy

This policy explains how Palatine keeps and disposes of personal data connected with our website, accounts, tracing, investigation and reporting services. It covers electronic records, paper records, correspondence, copies and backups.

It should be read with our Privacy Policy, which identifies the responsible legal entity and explains our purposes for processing, lawful bases, sharing arrangements and individuals' rights.

2. Our Retention Principles

We keep personal data only while it is needed for a specified, lawful purpose. Each record is assigned a category, retention period and deletion or review date. Where the purpose ends sooner, we delete the information sooner unless a separate requirement justifies retaining it.

Different parts of the same file may have different retention periods. We separate or redact shorter-lived information rather than keeping an entire file for the longest applicable period. Retaining an invoice, customer verification record or audit entry does not permit us to keep the underlying trace report for the same period.

The periods below are our standard schedule. Any longer period must have a documented justification and remain compatible with applicable law and service conditions. Where a shorter mandatory limit applies, that shorter limit takes priority.

3. Retention Schedule

Record category Standard retention period and starting point
Trace results and operational search information Deleted as soon as no longer needed and no later than 90 days from first receipt of the relevant information. This includes reports, downloads, screenshots, extracts and information reproduced in other documents. A shorter service period applies where specified.
Other independently obtained case material Kept while needed to perform the instruction, then normally deleted within 90 days of case closure. A different justified period may be recorded for the particular instruction. Any trace results within the file remain subject to their separate 90 day limit from first receipt.
Customer verification and eligibility evidence Kept throughout the active customer relationship and for at least 36 months after it ends. The standard post-termination period is 36 months, followed by deletion unless a separate, documented legal or compliance requirement applies.
Minimum transaction and service audit records Transaction records are normally kept for 36 months from the transaction. Audit findings are normally kept for 36 months from completion of the review. Only necessary identifiers, access details, purpose, findings and disposal evidence are retained. Longer mandatory compliance periods apply only to the records they cover.
Formal compliance activity and related expenditure records Where required by the relevant service arrangement, kept while that arrangement remains in force and for five years after it ends. This covers necessary compliance and expenditure records, rather than ordinary trace results or complete case files.
Client contracts and administrative records Normally kept for six years after the last transaction. This covers the client relationship, contractual terms and necessary administrative correspondence. Operational case information and trace results follow their own shorter periods.
Invoices and accounting or tax records Kept for six years from the end of the last company financial year to which they relate, or longer where tax or accounting law requires. Billing records contain only the case reference and other information necessary for accounting.
Live account profiles and access credentials Kept while the account remains active and the information is needed. Access is disabled immediately when authorisation ends. Obsolete credentials and operational profile data are removed without undue delay. Necessary verification, audit and financial records follow their separate periods.
Enquiries which do not lead to an instruction Normally deleted within 12 months of the last meaningful contact, unless there is a continuing, documented reason to retain a limited record. Trace information supplied with an enquiry remains subject to the shorter trace information period.
Routine website and technical security logs Normally kept for no more than 90 days from creation. Relevant entries needed for an identified incident are placed in a restricted incident record and kept under the complaints and incident schedule. Service transaction audit records follow their separate period.
Complaints and data protection or security incident records Normally kept for three years after closure. A longer period applies only where necessary for a specific legal claim or legal or regulatory duty. Trace information is not kept beyond its separate deadline merely because an incident record remains open.
Marketing preferences and objection records Marketing contact details are reviewed at least annually and removed when no longer justified or when the relevant permission ends. A minimal suppression record is kept for as long as needed to respect an objection or opt-out. Cookie periods are described in our Cookie Policy.

4. Trace Information and Case Files

Operational trace information is subject to a maximum retention period of 90 days from first receipt. Service settings may provide for earlier deletion. Copying, downloading, forwarding, regenerating a report or keeping a case open does not restart that period.

The limit follows the information wherever it is stored, including customer portals, case systems, emails and attachments, exported documents, working notes, local devices, paper copies and backups. Independently received instructions and other case material are classified separately, with restricted trace information removed by its own deadline.

If a service arrangement ends and requires earlier disposal, use of the affected operational information stops immediately. The information and its copies or derivatives are returned or securely deleted as required, without undue delay and, in any event, within 30 days of termination or the earlier existing deletion deadline. Earlier return or deletion instructions are applied where required by the applicable conditions. Separately required customer verification and statutory records remain subject to their own schedules only where continued retention is lawful and permitted.

Clients receiving reports are responsible for the retention of their own copies under applicable law and service conditions. Their retention decisions do not extend the period for which Palatine may keep its copies.

5. Verification and Audit Evidence

Customer verification records contain the evidence needed to substantiate identity, business standing, eligibility and authorised use. Where applicable, they include approved verification reports and checks, the date performed, the identity or initials of the person performing the check and relevant supporting documents. Historical verification records are preserved alongside later updates for the required period.

The verification schedule applies to records which may lawfully and contractually be retained for that purpose. Ordinary trace outputs and subject profiles are not reclassified as verification evidence to extend their retention.

Service audit records are kept to the minimum needed to account for use and review its lawfulness. They identify the customer, user ID and registered individual, transaction reference, date and time, originating IP address and declared purpose or authorised use. Review findings, corrective actions and deletion confirmations are recorded where relevant.

6. Exceptional Retention and Preservation

A statutory duty, court order or other applicable legal preservation requirement may require specific information to be kept beyond its usual period. For information subject to the 90 day trace limit, an extension is made only where retention is required by law. A general wish to retain evidence, a possible future dispute, a customer preference or an audit request does not by itself extend that limit.

For other categories, necessary evidence may be retained for a specific legal claim or legal or regulatory requirement where lawful and permitted. Only the information needed for that purpose is placed in a restricted archive. It is not used for routine searches, fresh investigations, marketing or other unrelated purposes.

The reason, authority, scope, responsible person and next review date are recorded for each exception. We review continuing need at least quarterly and delete the information when the requirement ends. A preservation direction does not authorise retention of unrelated material.

7. Secure Disposal and Backups

Electronic information subject to a required purge is securely deleted, and paper records are securely shredded or destroyed. Other records may be irreversibly anonymised only where law and applicable conditions permit. Removing names from trace information does not replace a mandatory deletion requirement. Disposal covers duplicates, attachments, downloads and working copies; moving information into an archive or removing it from a portal is not, by itself, deletion.

Backup expiry and recovery arrangements must meet the final deletion deadlines in this policy. For trace information, that includes the 90 day deadline from first receipt. Where selective removal is unavailable, the affected backup is expired, overwritten or securely rendered irrecoverable by the deadline; there is no additional backup grace period.

Restoration of a backup must not bring expired or erased information back into operational use. Outstanding deletion requirements are reapplied before restored information is made available. Disposal records identify the category or reference, date, method and outcome without retaining a fresh copy of the deleted content.

8. Account Closure and Ongoing Review

Closing an account or ending a user's authority triggers immediate removal of access and a review of the associated information. We delete operational information and retain only records still needed under the applicable schedule. Dormant accounts are reviewed at least annually; absence of a deletion request is not a reason to retain personal data indefinitely.

We review retention and disposal compliance at least quarterly, including service use, expiry dates, exceptional archives and outstanding deletion actions. The policy and schedule are reviewed at least annually and when services, legal duties or relevant conditions change.

9. Requests About Your Information

You may ask us about information we retain or request access, correction, erasure or restriction. We assess each request under applicable data protection law and explain any lawful reason for retaining information. We normally respond within one month, subject to any extension or other timing provision permitted by law.

Where we act on behalf of another controller, we assist that controller with the request in accordance with our role and instructions. Where notification to recipients of an erasure is required, we take the necessary steps. You may also raise a concern with the Information Commissioner's Office.

10. Contact

Please contact Palatine with questions about this policy or our handling of your information.