How long we keep your data

1. Purpose

We provide technology used by career coaches, career practitioners and other organisations to manage client relationships, cases, communications, assessments, documents, meetings and related professional activities.

In providing these services, we store and process information on behalf of our customers. Some of this information may constitute personal information or sensitive information.

This policy establishes the principles and requirements governing:

• where and how data is stored;
• how long data is retained;
• the responsibilities of us and our customers;
• backup and recovery data;
• customer access and export;
• deletion of data;
• account termination;
• legal retention requirements;
• data held by service providers and subprocessors; and
• continuity and data access should we cease providing the service.

This policy is intended to ensure that information is retained only for legitimate purposes and for no longer than necessary, while maintaining appropriate availability, security and resilience.

2. Scope

This policy applies to information stored or processed by us in connection with the Voyj platform and associated services.

This includes, where applicable:

• organisations and user accounts;
• client records;
• case records;
• contact information;
• notes;
• goals and action plans;
• assessments and assessment results;
• documents and attachments;
• email and communication records;
• calendar and appointment information;
• meeting information;
• audio and video recordings;
• transcripts;
• system-generated records;
• audit and security logs;
• configuration information; and
• backups containing any of the above.

This policy applies to production systems and to supporting infrastructure operated by us or by third-party service providers acting on our behalf. It does not establish retention requirements for copies of information exported from Voyj and subsequently held by a customer outside the Voyj platform.

3. Policy Principles

We apply the following principles to the storage and retention of information.

4. Roles and Responsibilities

5. Storage of Customer Data

6. Customer Data Retention

7. Our Business and Operational Records

Some information generated through operation of Voyj is retained independently of the customer’s underlying content.

This may include:

• subscription and billing records;
• invoices and transaction records;
• contractual records;
• authentication records;
• security events;
• audit records;
• service activity records;
• support correspondence; and
• records required to establish or defend legal rights.

These records may be retained after customer content has been deleted where reasonably required for:

• legal or regulatory compliance;
• taxation and accounting;
• fraud prevention;
• security;
• audit;
• dispute resolution; or
• establishment, exercise or defence of legal claims.

Retention of such records must be limited to information reasonably necessary for the relevant purpose. Where possible, operational records should avoid retaining the underlying customer content itself.

8. Backups and Recovery

9. Data Export

10. Account Termination

11. Legal Holds and Required Retention

Deletion or automated retention processes must be suspended where we are legally required to preserve particular information.

This may occur in response to:

• a court order;
• subpoena or other compulsory legal process;
• applicable statutory requirements;
• a regulatory requirement;
• an active legal dispute; or
• a reasonably anticipated legal proceeding requiring preservation of evidence.

A legal hold must apply only to information reasonably within the scope of the preservation requirement. When the requirement ends, the information must return to its ordinary retention lifecycle unless another lawful basis for retention exists. We will not retain customer information indefinitely merely because it might conceivably become relevant to a future dispute.

12. Destruction and De-identification

We will take reasonable steps to destroy or appropriately de-identify personal information when it is no longer required for an authorised purpose and is not required to be retained by law.

Deletion must address information under our control across relevant systems, including third-party systems where applicable.

Technical limitations may mean that deletion occurs progressively rather than instantaneously.

Where immediate physical destruction is impractical, information must be placed beyond ordinary use and remain protected until permanent deletion occurs through the applicable lifecycle.

De-identified information may be retained where there is a legitimate purpose for doing so, provided that we have taken reasonable steps appropriate to the circumstances to prevent individuals from being reasonably identifiable.

We must not describe information as anonymous or de-identified where there remains a material and reasonably practicable means of identifying the individual.

13. Service Providers and Subprocessors

We remain responsible for managing the lifecycle of information entrusted to service providers acting on our behalf to the extent required by applicable law and our contractual arrangements.

We must consider a provider’s ability to:

• appropriately protect information;
• restrict its use;
• meet relevant data location requirements;
• return or export information;
• delete information;
• manage backups appropriately; and
• apply equivalent obligations to relevant subcontractors.

We must not intentionally retain information indefinitely within a third-party service after the information has been deleted from Voyj merely because deletion from that provider is inconvenient.

14. Security Logs and Audit Information

Security and audit logs may require different retention periods from customer content.

Logs should contain only the information reasonably necessary for their operational and security purpose.

Where practicable, sensitive customer content should not be written to application, diagnostic or security logs.

Logs may be retained for purposes including:

• security monitoring;
• incident investigation;
• fraud detection;
• troubleshooting;
• auditing; and
• demonstrating compliance.

Log retention periods must balance these requirements against privacy, security and storage risks.

15. Development and Test Environments

Production customer information must not routinely be copied into development or test environments.

Where production information is exceptionally required for diagnosis or testing:

1. its use must be authorised;
2. only the minimum necessary information may be used;
3. access must be restricted;
4. de-identification or masking must be used where practicable; and
5. the information must be removed when the authorised purpose has been completed.

Synthetic or appropriately de-identified test data should be used wherever reasonably possible.

16. Voyj Service Discontinuation

We recognise that customers may rely upon the platform to hold important business and client records.

We must therefore maintain reasonable business continuity arrangements addressing the possibility that we permanently discontinue the service.

Where we make a planned decision to discontinue the service, we will seek to provide customers with reasonable advance notice and an opportunity to export their information.

Our continuity objective is to provide customers with at least 90 days, where reasonably practicable, in which to retrieve or export their data following notice of permanent service discontinuation.

We will maintain data export capabilities as a core part of our continuity strategy.

Nothing in this policy constitutes a guarantee that we can continue operating our full application platform for a particular period following insolvency, external administration, catastrophic failure or circumstances outside our reasonable control.

Instead, our continuity planning will prioritise preservation of customer access to, and export of, customer data.

Where appropriate, we may maintain technical or operational arrangements designed to allow limited data retrieval or export independently of normal application operations.

17. Insolvency

If we become insolvent or enter external administration, customer information does not become our property merely because it is stored on Voyj infrastructure.

Subject to applicable law and the authority of any appointed administrator, liquidator or other controller, our continuity arrangements should prioritise:

1. maintaining the security and integrity of customer information;
2. notifying customers where reasonably possible;
3. maintaining or establishing a mechanism for customer export;
4. providing a reasonable period for retrieval where circumstances permit; and
5. securely disposing of remaining customer information when continued retention is no longer required.

We will design our systems and operational procedures with the objective that customer data portability does not depend solely upon our continued operation as a going concern.

18. Security Incidents

A security incident does not automatically alter the applicable retention period.

Information relevant to investigation of an incident may, however, be preserved for longer than its normal retention period where reasonably required for:

• investigation;
• remediation;
• regulatory reporting;
• insurance;
• law enforcement;
• legal proceedings; or
• demonstrating the actions taken by us.

Any such extended retention must be proportionate to the purpose.

19. Exceptions

Exceptions to this policy must be:

• justified by a legitimate business, technical or legal requirement;
• appropriately risk assessed;
• approved by an authorised representative of ours; and
• documented where material.

An exception must not be used merely to avoid implementing a reasonable deletion or retention control.

20. Compliance and Review

We will periodically review our information storage and retention practices to ensure they remain appropriate to:

• the nature and scale of the Voyj service;
• the information being processed;
• customer requirements;
• contractual obligations;
• technological changes;
• security risks; and
• applicable laws and regulations.

Material changes to infrastructure or service providers must include consideration of their impact on storage, retention, deletion, recovery and data residency. This policy will be reviewed at least annually.

21. Relationship With Our Other Policies

This policy should be read together with our:

• Privacy Policy;
• Information Security Policy;
• Artificial Intelligence Policy;
• Business Continuity and Disaster Recovery arrangements;
• Terms of Service;
• Data Processing Agreement, where applicable; and
• applicable customer agreements.

Where another binding agreement establishes a specific retention requirement, that requirement takes precedence to the extent of any inconsistency with this general policy. Applicable law always takes precedence over this policy.

22. Definitions

Active systems

Production systems used in the normal operation of Voyj and from which information is ordinarily accessible.

Backup

A copy of information maintained primarily for system recovery, disaster recovery or business continuity.

Customer

An organisation or individual that has entered into an agreement to use Voyj.

Customer data

Information submitted to, generated through or stored within Voyj on behalf of a customer, excluding information generated and held solely for our own corporate purposes.

De-identification

A process intended to ensure that information is no longer about an identifiable or reasonably identifiable individual.

Deletion

Removal of information from ordinary operational use, followed by destruction, expiry or other measures appropriate to the system in which the information is held.

Legal hold

A temporary suspension of ordinary deletion processes where information must be preserved for a legal, regulatory or dispute-related purpose.

Personal information

Information or an opinion about an identified individual, or an individual who is reasonably identifiable, as defined by applicable Australian privacy law.

Production data

Information held within our live production environment.

Retention period

The period for which information is maintained before deletion or de-identification.

Sensitive information

Information falling within the definition of sensitive information under applicable Australian privacy law.

23. Policy Statement

Our approach to data retention is based on a simple principle:

We will provide customers with control over their records, reasonable data portability, appropriate resilience and backup, and a defined path for deletion. We will not use indefinite retention as a substitute for proper information lifecycle management.

24. Applicable Law and Jurisdiction

We are an Australian-operated service and this policy is established with reference to applicable Australian laws and regulatory requirements, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Where we provide services to customers or process personal information subject to the laws of another jurisdiction, additional legal or contractual requirements may apply.

Nothing in this policy is intended to limit any rights or obligations that cannot lawfully be excluded or modified under applicable law.

Where a customer agreement establishes specific data residency, retention, deletion or regulatory requirements, those requirements apply in addition to this policy and prevail to the extent of any inconsistency.