Data Retention Policy
Effective Date: 5 May 2025 | Version: 1.0
Kliksend (Pty) Ltd
127 Kenneth Road, Greenhills, Randfontein, Gauteng, 1759
📧 Email: info@kliksend.co.za | 📞 Phone: 066 513 1357
1. Purpose
This policy establishes guidelines for the retention, review, and secure disposal of personal and business information processed by Kliksend (Pty) Ltd (“Kliksend”) in accordance with:
- The Protection of Personal Information Act (POPIA)
- The Promotion of Access to Information Act (PAIA)
- Other applicable South African laws
2. Scope
This policy applies to:
- All data processed by Kliksend, including data from users, employees, service providers, and third parties
- All data formats (electronic and physical)
- All systems, devices, cloud services, and backups storing or transmitting data on behalf of Kliksend
3. Definitions
- Last Interaction: The last date a user logs in, uploads/transfers data, communicates with Kliksend, or interacts with marketing content
- Data Mapping Register: An inventory of data categories, sources, processing purposes, and retention periods maintained by Kliksend
- Backup Archive: A secure, time-limited copy of operational data stored for business continuity
4. Data Retention Schedule
| Category | Retention Period | Legal / Operational Basis |
|---|---|---|
| Client & Uploaded File Data | 3 years from last interaction (extendable to 5 if active account/legal necessity) | Operational need; POPIA; risk mitigation |
| User Account Metadata (login records, file transfer logs) | 2 years | POPIA, cybersecurity auditing |
| Financial Records | 7 years | Income Tax Act, Companies Act |
| Personnel Files | 5–7 years post-employment | BCEA, Labour Relations Act |
| CVs & Job Applications | 1 year | POPIA (future opportunities) |
| CRM / Marketing Data | Until consent withdrawn or 2 years after last activity | POPIA – consent & legitimate interest |
| Email Records | 3–5 years (based on content sensitivity) | Internal policy, legal risk |
| IT Backups | 6 months – 1 year (automated purge) | Business continuity |
| Service Provider Agreements | 7 years after termination | Contractual enforcement |
| Cookies & Analytics Data | 12–24 months | Industry standard / POPIA |
| Records of PAIA/POPIA Requests | 3 years | Compliance documentation |
5. Data Disposal and Destruction
Kliksend uses the following secure destruction methods:
- Electronic Data: Deleted using tools compliant with NIST 800-88 or DoD 5220.22-M standards
- Physical Records: Shredded or destroyed via certified disposal contractors
- Backups: Encrypted, time-limited, and purged via automated cycles; sensitive data anonymized where feasible
Disposal logs are maintained for audit purposes. Annual third-party validation is performed where required.
6. Special Data Categories
6.1 Children’s Data: Kliksend does not knowingly collect data from individuals under 18 without parental consent. Where processed, such data is retained only for the minimum required period and securely destroyed thereafter.
6.2 Cross-Border Transfers: Personal data stored on foreign servers (e.g., cloud platforms) is subject to Section 72 of POPIA. Kliksend ensures transfers only to countries with adequate protection or via enforceable contractual safeguards.
7. Data Subject Rights
All data subjects have the right to:
- Request access to their data
- Request corrections or deletions
- Object to processing or retention
- Withdraw consent
Requests can be submitted in writing to:
📧 Email: info@kliksend.co.za
📞 Phone: 066 513 1357
📍 Address: 127 Kenneth Road, Greenhills, Randfontein, Gauteng, 1759
Kliksend maintains a Data Subject Request Register and responds within 30 days in line with PAIA and POPIA requirements.
8. Governance and Monitoring
- Information Officer: Oversees policy enforcement and updates
- IT & Legal Teams: Manage technical and compliance controls
Annual Review: This policy and the Data Mapping Register are reviewed annually or upon major changes in law or operations.
9. Policy Approval
Approved by: ISAAC PETRUS STRAUSS
Designation: Information Officer
Date Approved: 6 May 2025
Next Review Date: 6 May 2026