Document Retention and Deletion Policy

This Document Retention and Deletion Policy explains how BARTONFREE ("BARTONFREE", "we", "us", or "our") handles client documents and related information during and after an engagement, including how long we keep materials and how we delete or return them. It should be read together with our Privacy Policy and our Confidentiality and Data Security Policy.

1. Purpose of this Policy

Good retention practices protect your privacy, reduce unnecessary duplication of your information, and help both parties understand what happens to documents over time. This Policy sets out our general approach; the specific handling for a given engagement may be described in your proposal or Service Agreement, which takes precedence where it differs from this Policy.

2. Working within your systems

Wherever possible, we work directly within the platforms and storage you control, so that your original documents remain in your own environment rather than being copied unnecessarily. In many engagements this means that the documents we organize never leave your systems, and there is little or no separate copy for us to retain.

3. Working copies and temporary materials

To perform certain tasks, we may create temporary working copies, drafts, notes, or exports. We keep these only as long as needed to complete the work and to support any review period that follows delivery. After that period, we take reasonable steps to delete temporary materials that are no longer required, unless we are asked to keep them or are required to retain them.

4. Retention during an engagement

During an active engagement, we retain the information necessary to deliver the services, communicate with you, and manage the project. This includes correspondence, project notes, and any access we have been granted to your systems, which remains in place only for as long as it is needed.

5. Retention after an engagement ends

After an engagement ends, we retain limited business records, such as proposals, invoices, and general correspondence, for as long as necessary to maintain our records, resolve any disputes, and meet our legal and tax obligations. We do not retain your substantive documents longer than necessary. Any access we held to your systems should be revoked by you promptly after handover, and we will also take steps on our side to relinquish access we no longer need.

6. Deletion and return of documents

At the end of an engagement, or upon your reasonable written request, we will delete or return the client materials in our possession that we are not required to retain, in a manner appropriate to the format and platform involved. Where documents live entirely within your own systems, deletion on our side primarily involves removing any working copies and relinquishing access. We will confirm the completion of a deletion or return request where practical.

7. Your responsibility for your own records

You are responsible for determining how long your business must retain its own documents and for meeting any legal or regulatory retention requirements that apply to you. We do not assess or advise on statutory retention periods. You are also responsible for maintaining independent backups, since our deletion of working copies is not a substitute for your own records.

8. Legal holds and exceptions

In limited circumstances we may be required to retain certain information beyond our normal periods, for example to comply with a legal obligation, respond to a lawful request, or protect our rights. In such cases we will retain only what is necessary and for only as long as required.

9. Backups and residual copies

Where information has been included in routine system backups, it may persist in those backups for a limited time after deletion from active systems, consistent with standard backup cycles. Such residual copies are protected in the same way as other confidential information and are overwritten or removed in the ordinary course.

10. Changes to this Policy

We may update this Document Retention and Deletion Policy from time to time. Changes will be reflected by the "Last updated" date above. We encourage you to review this Policy periodically.