Data Retention Policy

Data Retention, Archival, and Destruction Policy

Last updated: 06/10/2025

What is Data/Record Retention?

The retention period of data or a document is part of records information management. It defines how long a document should be kept, both electronically and in physical format. It includes:
1. How long each document or record is kept as an active record,
2. The reason (legal, fiscal, historical) for its retention, and
3. The final disposition (archival or destruction) of the record.

Policy

Active, inactive, and historical records must be maintained in accordance with the Record Retention Schedule and this Policy. Expired records are reviewed and destroyed upon management approval and in line with this Policy.

This Data Retention, Archival, and Destruction Policy requires Save My Tomato personnel to:
1. Retain important records for reference and future use.
2. Delete or destroy records no longer necessary for proper organizational function.
3. Suspend destruction of records upon notice from Save My Tomato Legal.
4. Enable departments to organize records for efficient retrieval.
5. Understand what records should be retained, for how long, and when/how they should be destroyed.

This Policy applies to all records, including electronic ones, and outlines retention periods and destruction protocols. It is designed to promote compliance with applicable laws, prevent accidental loss of information, and ensure consistent data handling.

Purpose

Save My Tomato acknowledges the importance of retaining records in a consistent, systematic, and reliable manner so they can be retrieved when needed for legal, regulatory, or operational reasons.

This Policy is intended to guide Save My Tomato staff in how to:
– Manage internal records throughout their lifecycle,
– Establish a data/records retention program,
– Define archival procedures, and
– Ensure proper destruction of data files.

Confidentiality Statement

At Save My Tomato, we are committed to responsible data management, which includes the use, protection, and deletion of both customer and company confidential information.

Responsibilities of Those with Access

Employees and business partners with access to information assets are responsible for their proper use, protection against unauthorized access or disclosure, and appropriate destruction.

Management Responsibilities

Save My Tomato senior management is responsible for identifying and enforcing proper retention and protection measures for all data assets. Management decisions must be guided by applicable laws and internal policies, and they must ensure that employees understand their responsibilities under this Policy.

Scope & Responsibility

The Chief Technology Officer (CTO) has primary responsibility for implementing and monitoring this Policy, along with security policies, practices, and related recordkeeping. The CTO also oversees the technical infrastructure for development and production environments, ensuring security standards are met.

This Policy applies to:
– All employees, contractors, consultants, and temporary staff working for or on behalf of Save My Tomato,
– All third-party partners and vendors,
– All information processed by production systems (financial, corporate, customer, and personal),
– Save My Tomato corporate and production systems, and
– Actions related to detecting, preventing, and responding to threats to these systems.

Data Retention Procedures

Customer data (e.g., usage metrics) is retained according to each customer’s requirements or agreements. This data is deleted upon customer request or as stipulated in the agreement. This excludes communications (e.g., emails, Slack messages).

– Customers must submit deletion requests via contact@savemytomato.com
– Data is deleted from primary systems within 30 business days of the request.
– Backup data is deleted within 60 business days.
– If requested, all Personally Identifiable Information (PII) for a specific employee will be deleted within the same timeframes.
– If requested, ingestion of future PII for that individual will also be halted.

Internal Deletion Procedures

Initial Notification
– The CTO must be informed before any data destruction.
– Engineering handles electronic data; business units manage physical records.
– Engineering must complete the request within the prescribed timeframe.

Ticketing Process
– If a request is submitted via JIRA, it is assigned to Engineering.
– Requests via email must be forwarded and logged in JIRA.
– Desktop Support must link external emails to the appropriate JIRA ticket and forward to Engineering.

Proof of Request
To verify deletion, the following must be included in the JIRA ticket:
– A copy of the client’s written request (email, letter, or memo).
– A note from the Account Manager if the request was made verbally.

Deletion of Electronic Records
Once documented, Engineering will delete the data from production and archival locations.

Destruction Notification
– Attach screenshots of deleted virtual machines (VMs) or data folders to the JIRA ticket.
– Notify the customer within 30 days that their data has been deleted.

Who Should Read This Policy

This Policy should be read by:

Save My Tomato Management
– To ensure data retention, archival, and destruction requirements are addressed and updated.

Save My Tomato Teams
– To implement and maintain consistent retention and destruction practices.

Enforcement & Exceptions

Save My Tomato reserves the right to suspend, block, or restrict access to information assets when necessary to protect their confidentiality, integrity, or availability.

Violations of this Policy may result in disciplinary action, including termination, for both employees and contractors.

Policy Review & Updates

This Policy will be reviewed annually by the CTO or an assigned designee and updated as needed to reflect current business needs and regulatory requirements.