Noteable Service Retention Policy

Purpose and overview

The Noteable service will comply with data protection legislation by regularly deleting personal data it no longer requires1. This mainly relates to personal data held about users of the service and user activity.

This policy will reflect the subscriber’s user account expiry policy and records retention schedule. "Subscriber" and "user" will be differentiated as follows:

"Subscriber" is the customer, which is the organisation that has subscribed to the service

"User" is a login [taken to imply both a person, and singular] that originates through a Subscriber.

User account retention

The infrastructure that Noteable is built upon takes nightly backups of the virtual machines running the Noteable service. The service itself runs within Docker containers in those virtual machines. The backups are retained for 4 weeks.

The Noteable user account archival and deletion policy will be based upon the directives and guidance of the Noteable service team in agreement with the individual subscriber. As a general directive, the time schedules seen in the table below gives the following periods before user account deletion:

Expiry Period (Days) Suspension Period (Days) Total (days) Total (months)
User 150 30 180 6

Typically, access to services is maintained during the account expiry period. Users lose access to services during the account suspension period and deletion of the user account is completed at the end of the suspension period.

There may be an Identity Management System (IDM) feed into Noteable from the subscriber, upon a scheduled process can be arranged and run which will:

As part of IDM feed into Noteable, a scheduled process can be run which will:

Delete user accounts on Noteable completely, one year after user’s affiliation is set to ‘deleted’. Account deletion does not include deleting assignment work submitted to Instructors - this data is considered owned by the relevant Instructor.

Assignments and Gradebook Retention

Yearly housekeeping

All users with Instructor status have additional files & folders in their home directory:

These documents are all personal to the instructor, and not accessible elsewhere. Instructors are advised to manually copy, towards the end of every year of subscription to the Noteable service, the gradebook and students ‘collected’ and graded assignments within their repository, to their respective Admin Teaching Office and then delete the same from their repository.

Noteable will delete records on a per assignment basis 1 year after the last action for an assignment, then all records for that assignment are deleted.

Student Data Deletion

When a student account is deleted, the repository associated with that student will be deleted completely and this will include their own notebooks and any assignments stored within the repository.

Staff Deletion

When an instructor is due to leave the subscriber’s institution, they are advised to copy all graded assignments, feedback assignments and the gradebook file manually to their respective Admin Teaching Office. The instructor repository will then be deleted automatically as per the account retention policy above.

System Data Retention

Logs which contain user activity will be anonymised or purged one year after creation in line with the structures explained above.

System Data Retention for Service Operations

All elements of submission and assignment activity (including feedback) held by Noteable will be kept for 5 years then anonymised or purged.

This policy was approved on June 20th, 2020 by EDINA management and is effective from June 20th, 2020.

Amendments:

Next review due: June 19th, 2021

If you require this document in an alternative format, please email edina@ed.ac.uk or telephone +44 (0)131 650 3302


[1] : https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/