Review draft. Customer and merchant agreements take effect only after legal approval, publication and any required acceptance.
Record categories and purpose
Maintain an inventory of website security records, enquiries, account and authorization data, identity evidence, payment and ledger records, and complaints. Assign a purpose, responsible controller, lawful basis, access role and retention rule to each category.
Retention rules
Set a duration or objective criteria for each record type. The responsible entity should consider applicable payment, AML, accounting and dispute requirements. Stop or defer deletion only for a documented lawful reason such as a valid legal hold, then review that hold.
Security, deletion and transfers
Apply role-based access, secure storage and records of access where appropriate. Delete or irreversibly anonymize records when the approved rule expires, and address backup lifecycle and restoration. Document processor responsibilities, international transfer safeguards and incident handling.
Reviewing the retention schedule
Record the start event for each retention period and the approved disposal method. If retained data is restored from a backup, reapply any applicable access limits, deletion instructions and legal holds before resuming ordinary processing.
Requests and oversight
Verify the requester through an approved proportionate process, log decisions and apply rights and any lawful exceptions. Publish the controller’s verified contact, escalation route and current retention information before processing relevant customer records.
Approval and publication requirements
Approve a record-by-record data inventory, lawful bases, processors, transfer assessment, retention periods, deletion controls and authorized contacts.