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Effective date: December 2025
This Data Retention, Review and Disposal Policy (“Retention Policy”) sets out the principles, rationale, and procedures adopted by Red Rose UK in relation to the retention, review, restriction, and disposal of personal data processed through its platform.
This Policy is intended to demonstrate compliance with the storage limitation principle under Article 5(1)(e) UK GDPR, as well as the additional safeguards required when processing criminal offence data under Article 10 UK GDPR and the Data Protection Act 2018.
The purpose of this Retention Policy is to ensure that personal data processed by Red Rose UK is:
This Policy applies to all personal data processed by Red Rose UK, including:
This Policy is informed by and implemented in accordance with:
Red Rose UK recognises that while the ROA limits when individuals are required to disclose spent convictions in certain legal contexts, it does not impose a general prohibition on the lawful processing or publication of conviction data for safeguarding and public interest purposes.
Red Rose UK does not apply rigid, arbitrary, or purely time-based retention periods to personal data.
Instead, retention decisions are based on an assessment of:
Data is retained only where continued processing is assessed as necessary, proportionate, and justified.
Red Rose UK retains criminal offence data only in relation to defined categories of serious offending, namely:
These categories reflect offences assessed as presenting a heightened and ongoing risk to vulnerable individuals or the wider public.
Criminal offence and conviction data falling within the above categories is retained indefinitely.
Red Rose UK considers that the serious nature of these offences, combined with the legitimate safeguarding purposes of the platform, justifies long-term retention in the substantial public interest.
Retention is not determined solely by the passage of time or by whether a conviction becomes “spent” under the Rehabilitation of Offenders Act 1974.
Red Rose UK does not remove conviction data solely on the basis that a conviction has become spent under the Rehabilitation of Offenders Act 1974.
This position is adopted on the basis that:
Each category of offence retained by Red Rose UK has been assessed as carrying long-term relevance to safeguarding.
Where individuals are listed as charged but not yet convicted, Red Rose UK retains the information to reflect the factual existence of the charge as recorded in verified sources.
Charge data is retained to support awareness and transparency, particularly where allegations relate to safeguarding concerns.
Where proceedings result in acquittal, discontinuance, or no further action, Red Rose UK updates the profile to reflect the outcome where verified.
Profiles are not routinely removed following acquittal. The retention of such information is assessed on the basis of:
Retention of acquittal information does not imply guilt and is presented as a factual record of proceedings.
User-generated content, including telephone numbers, social media details, and full address information, is retained subject to feasibility of moderation and review.
Due to the volume and decentralised nature of submissions, Red Rose UK cannot guarantee continuous or immediate moderation of all user-generated content.
Where such content is identified as inaccurate, excessive, or unlawful, it may be restricted or removed following review.
Red Rose UK does not apply fixed retention periods to user-generated content but retains discretion to remove or anonymise such data where appropriate.
Facial templates derived from images associated with verified profiles are retained for as long as the corresponding profile remains active on the platform.
Images uploaded by users for facial recognition comparison are retained for a maximum of 24 hours and are automatically deleted thereafter.
User-uploaded images are not used to create new biometric profiles and are not retained beyond the defined deletion period.
User account data, including names, email addresses, IP addresses, and basic user-agent data, is retained for as long as the user account remains active.
Where an account is closed, associated data may be retained where necessary for:
Red Rose UK undertakes periodic internal reviews of retained data to assess ongoing relevance and proportionality.
Reviews may be triggered by:
Where personal data is no longer required for safeguarding or public interest purposes, Red Rose UK may:
Disposal methods are designed to ensure that data is securely and irreversibly removed where appropriate.
Decisions relating to retention, restriction, or disposal of data are overseen by the Data Protection Officer.
All material changes to retained data are logged for audit and accountability purposes.
This Retention Policy operates alongside Red Rose UK’s Data Subject Rights and Erasure Handling Policy.
Retention decisions do not override data subject rights but inform how such rights are assessed in light of safeguarding and public interest considerations.
This Policy is reviewed periodically and updated as necessary to reflect changes in law, guidance, or operational practice.