Data Retention & Disposal Policy

Version 1.0 — Last updated July 2026. Reviewed at least annually.

1. Purpose & scope

This policy defines how long our organization retains the personal and financial data it collects to operate as a staffing agency, and how that data is securely disposed of when it is no longer needed. It applies to data about applicants, talent-pool registrants, placed employees, client contacts, and financial/banking data used for accounting and reconciliation. It is designed to comply with applicable data-privacy laws (including CCPA and analogous state laws) and with federal and state record-retention requirements for employment and payroll.

2. Principles

• Purpose limitation: data is retained only as long as needed for the purpose it was collected, or as required by law.
• Least data: we do not retain personal data indefinitely "just in case."
• Secure disposal: when a retention period ends, data is deleted or irreversibly anonymized.
• Auditability: retention and disposal actions are recorded so the policy can be evidenced.

3. Retention schedule

Data category	Retention period	Basis
Talent-pool registrations (candidates not yet placed)	Up to 2 years from last contact; auto-archived after 180 days of inactivity, purge-warned ~30 days prior, then purged	Business need + consent given at registration
Applicant records	Minimum 1 year from the application/decision (2 years where federal-contractor rules apply)	EEOC / OFCCP recordkeeping
Employee payroll & tax records (placed workers)	Typically 4–7 years after termination	IRS (4 yrs), FLSA/DOL (3 yrs), state wage & unemployment rules
Form I-9 & work-authorization documents	3 years after hire date, or 1 year after termination — whichever is later	USCIS / IRCA
Financial & banking records (invoices, GL, bank-feed transactions)	Retained for the accounting record period (generally 7 years)	Tax / accounting requirements
Bank connection credentials (Plaid access tokens)	Deleted immediately when the bank connection is disconnected	Least-privilege; no longer needed

4. Disposal & anonymization

• Automated purge: when a talent-pool record reaches the end of its window, personal identifiers are irreversibly anonymized (name and email replaced with non-identifying placeholders); the de-identified row may be kept for aggregate funnel analytics only.
• Documents: uploaded identity/onboarding documents are stored encrypted at rest and are deleted from the document store on disposal or on an honored deletion request.
• Bank data: disconnecting a bank connection deletes its stored account and transaction records and the associated Plaid access token.
• Cryptographic protection of disposal: sensitive data at rest is encrypted with AES-256-GCM, so residual copies are unreadable without the key.

5. Enforcement

Retention windows are enforced by an automated retention engine in the application (configurable under Settings → Retention Policy), which archives, warns, and purges records on schedule without relying on manual action. Retention and disposal events are written to an audit log to provide an evidence trail. A staff member may place an active record on a temporary hold (a "legal hold") to pause automatic disposal where an ongoing matter requires it.

6. Individual rights & deletion requests

Individuals may request access to, correction of, or deletion of their personal data as described in our Privacy Statement. Deletion requests are honored except where a law (for example, payroll or tax record-keeping for an actual employee) requires continued retention; in that case only the legally required minimum is kept, and the rest is disposed of.

7. Review

This policy is reviewed at least annually, and whenever applicable data-privacy or record-retention laws change or our data practices materially change. The retention windows configured in the application are checked against this policy at each review.

8. Contact

Questions about this policy, or to make a data-rights request, contact privacy@midsouthtalent.com.

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