Data Retention & Deletion Policy

1. Purpose and scope

This policy governs how long UniMatter retains information, the basis on which retention periods are set, and the manner in which information is securely deleted or de-identified once it is no longer required. It gives effect to Australian Privacy Principle 11.2, which requires that personal information be destroyed or de-identified when it is no longer needed for any purpose for which it may be used or disclosed, subject to any law or court or tribunal order requiring its retention.

This policy applies to all information held by UniMatter in any format, including production data, backups, working copies, correspondence, and logs, and to information held on the firm’s behalf by approved subprocessors.

2. Retention principles

UniMatter retains information only for as long as there is a lawful and operational basis to do so. Retention periods are set by reference to the purpose of collection, the duration and nature of the engagement, applicable legal and regulatory retention obligations, and the firm’s legitimate need to defend or assert legal claims.

1. Information is retained for the minimum period necessary to fulfil the purpose for which it was collected.
2. Where a statutory or contractual retention period applies, that period governs and is recorded against the relevant data category.
3. Information subject to a legal hold is retained until the hold is lifted, irrespective of the ordinary retention period.
4. Where retention is no longer justified, information is securely deleted or irreversibly de-identified.

3. Retention schedule

UniMatter maintains a retention schedule that records, for each category of information, the applicable retention period and its basis. The periods below are illustrative of the firm’s default approach and are subject to the schedule and to any overriding legal obligation.

1. Client engagement records and deliverables: retained for the duration of the engagement and for seven years thereafter, consistent with limitation and professional-record considerations.
2. Personal information processed on behalf of a client: retained per the client agreement and returned or deleted on conclusion of the engagement.
3. Financial and taxation records: retained for the period required under applicable Commonwealth taxation law.
4. Security and access logs: retained for a defined operational period sufficient to support incident investigation and audit.
5. Marketing and enquiry contact details: retained until consent is withdrawn or the contact is no longer active.

4. Secure deletion and de-identification

When information reaches the end of its retention period, it is securely deleted or irreversibly de-identified. Secure deletion is performed using methods appropriate to the storage medium so that the information cannot be reconstructed or recovered through ordinary means.

De-identification is treated as effective only where the residual data cannot reasonably be re-identified, taking account of other information reasonably available. Where genuine de-identification cannot be assured, the information is deleted instead.

5. Backups and archives

Information held in backups and archives is subject to this policy. Where information is deleted from a production system but persists in a backup, it is overwritten or expires in the ordinary backup-rotation cycle, and is not restored into production except where a legitimate basis to do so subsists.

Backup-retention periods are set so that the firm can recover from operational failure without retaining personal information beyond what is necessary.

6. Return and deletion on engagement closure

On conclusion of a client engagement, UniMatter returns or deletes client data in accordance with the client agreement. Where the client agreement is silent, the firm’s default is to return or delete client-controlled personal information and to retain only the records reasonably necessary for the firm’s own legal, taxation, and professional purposes.

A certificate of deletion is provided on request where the firm is able to attest to the deletion performed.

7. Requests for correction and erasure

An individual may request access to, or correction of, their personal information in accordance with Australian Privacy Principles 12 and 13. Where UniMatter processes personal information on behalf of a client, such requests are referred to the client as controller, and the firm assists the client in responding.

Where the firm is the controller of the information, it responds to access and correction requests within a reasonable period and free of excessive charge, consistent with its obligations under the Privacy Act 1988 (Cth).

8. Roles and review

The principal is accountable for the operation of this policy and for maintaining the retention schedule. The schedule is reviewed at least annually and on any material change to the firm’s engagements, systems, or legal obligations.

Enquiries concerning retention or deletion of information may be directed to UniMatter at administrator@unimatter.com.au.