SmartFace Attendance

Data Retention Policy - SmartCarePlus

1. Introduction

This Data Retention Policy outlines how SmartFace Attendance collects, retains, and disposes of personal data, including biometric information. This policy ensures compliance with legal requirements, protects user privacy, and maintains operational efficiency.

2. Purpose and Scope

2.1 Purpose

This policy aims to:

Define retention periods for different types of data
Ensure compliance with employment, tax, and data protection laws
Minimize data storage to reduce privacy risks
Establish clear procedures for data deletion and archival
Support audit and legal discovery requirements

2.2 Scope

This policy applies to:

All personal data collected through SmartFace Attendance
All users including administrators, employees, and system operators
All data stored in MongoDB databases and file storage systems
All components: Backend API, Face Recognition Service, and Mobile Application

3. Data Categories and Retention Periods

3.1 User Account Data

Company/Organization Administrator Accounts

Data Types: Company name, administrator name, email, WhatsApp number, subscription details
Retention Period: Duration of active subscription plus 3 years
Deletion Trigger: 3 years after subscription cancellation or account closure
Legal Basis: Contract performance, tax and audit requirements
Notes: Financial records retained separately as per tax law (7 years)

Authentication Tokens

Data Types: Laravel Sanctum tokens, device tokens
Retention Period: Until token expiration or user logout
Deletion Trigger: Immediate upon logout or 90 days of inactivity
Legal Basis: Security and access control

3.2 Employee/Staff Data

Core Employee Information

Data Types: Name, employee ID, email, phone, department, position, salary
Retention Period: Duration of employment plus 7 years
Deletion Trigger: 7 years after employment termination
Legal Basis: Employment law, tax compliance (salary records), legal claims
Notes: Aligns with statutory requirements for employment records in most jurisdictions

Employee Status Changes

Data Types: Department transfers, shift changes, status updates
Retention Period: Same as core employee information (7 years post-employment)
Deletion Trigger: 7 years after employment termination

3.3 Biometric Data (Critical)

Facial Images (Enrollment Photos)

Data Types: 3-10 facial photographs per employee
Retention Period: Duration of employment only
Deletion Trigger: 30 days after employment termination
Legal Basis: Biometric consent, employment contract
Notes: Subject to strict biometric privacy laws (e.g., BIPA, GDPR Article 9)
Storage Location: Encrypted file storage with restricted access

Facial Recognition Embeddings

Data Types: Mathematical facial feature vectors stored in MongoDB
Retention Period: Duration of employment only
Deletion Trigger: 30 days after employment termination
Legal Basis: Biometric consent, employment contract
Notes: Deleted from all databases including primary and backup systems

Face Recognition Logs

Data Types: Recognition attempts, confidence scores, matched/unmatched events
Retention Period: 90 days
Deletion Trigger: Automatic deletion after 90 days
Legal Basis: System security, troubleshooting, fraud prevention
Notes: Contains only metadata, not biometric templates

3.4 Attendance Records

Daily Attendance Logs

Data Types: Check-in/check-out timestamps, type (entry/exit), device ID, confidence scores
Retention Period: Employment duration plus 7 years
Deletion Trigger: 7 years after employment termination
Legal Basis: Employment law, payroll compliance, tax audits, legal disputes
Notes: Required for wage/hour law compliance and potential disputes

Attendance Summaries and Reports

Data Types: Monthly calendars, working hours, overtime, late arrivals, salary estimations
Retention Period: Employment duration plus 7 years
Deletion Trigger: 7 years after employment termination
Legal Basis: Payroll records, employment law compliance

Exported Attendance Data (Excel files)

Data Types: User-generated exports of attendance records
Retention Period: 30 days in system storage (user's local copy not controlled)
Deletion Trigger: Automatic deletion 30 days after generation
Notes: Users responsible for their downloaded copies

3.5 Subscription and Billing Data

Subscription Records

Data Types: Plan details, pricing, start/end dates, status
Retention Period: Subscription period plus 7 years
Deletion Trigger: 7 years after subscription ends
Legal Basis: Tax law, financial audits, contract disputes

Payment Transaction Records (if payment processing is added)

Data Types: Transaction IDs, amounts, dates (no credit card details stored)
Retention Period: 7 years
Deletion Trigger: 7 years from transaction date
Legal Basis: Tax compliance, financial regulations

3.6 Device and Terminal Data

Device Registration Information

Data Types: Device name, location, device token, status
Retention Period: Duration of device active status plus 1 year
Deletion Trigger: 1 year after device deactivation
Legal Basis: System operations, security audits

Device Activity Logs

Data Types: Last activity timestamps, authentication attempts
Retention Period: 90 days
Deletion Trigger: Automatic deletion after 90 days
Legal Basis: Security monitoring, troubleshooting

3.7 System Logs and Technical Data

API Access Logs

Data Types: API requests, response codes, timestamps, user agents
Retention Period: 90 days
Deletion Trigger: Automatic deletion after 90 days
Legal Basis: Security monitoring, debugging, performance optimization

Error and Debug Logs

Data Types: Application errors, stack traces, system events
Retention Period: 90 days
Deletion Trigger: Automatic deletion after 90 days
Legal Basis: System maintenance, troubleshooting

Security Audit Logs

Data Types: Authentication attempts, authorization failures, suspicious activities
Retention Period: 2 years
Deletion Trigger: 2 years from log creation
Legal Basis: Security investigations, compliance audits, legal requirements

Database Backups

Data Types: Complete system backups including all data
Retention Period: 30 days (rolling backups)
Deletion Trigger: Automatic deletion of backups older than 30 days
Legal Basis: Disaster recovery, business continuity
Notes: Biometric data in backups subject to special handling

3.8 Verification and Password Recovery Codes

WhatsApp Verification Codes

Data Types: 6-digit verification codes for account registration
Retention Period: 10 minutes
Deletion Trigger: Immediate after verification or 10-minute expiration
Legal Basis: Account security

Password Recovery Codes

Data Types: 6-digit recovery codes for password reset
Retention Period: 30 minutes
Deletion Trigger: Immediate after use or 30-minute expiration
Legal Basis: Account security

3.9 Shift and Department Data

Department and Shift Configurations

Data Types: Department names, shift timings, weekly holidays, overtime rules
Retention Period: Duration of use plus 3 years
Deletion Trigger: 3 years after deletion from active system
Legal Basis: Historical reference, payroll audits

4. Data Deletion Procedures

4.1 Automated Deletion

Scheduled Jobs: Automated cron jobs run daily to delete expired data
Token Cleanup: Authentication tokens purged upon logout or expiration
Log Rotation: System logs automatically rotated and deleted per retention schedule
Backup Rotation: Old backups automatically deleted after 30 days

4.2 Manual Deletion (User-Initiated)

Employee Departure: HR/Admin triggers employee termination workflow
30-Day Grace Period: Biometric data retained for 30 days for potential disputes
Confirmation Required: Two-step confirmation for biometric data deletion
Audit Trail: All manual deletions logged with user ID and timestamp

4.3 Right to Deletion (GDPR/Privacy Laws)

User Request: Users can request deletion of their personal data
Identity Verification: Request authenticated via system login or identity verification
Legal Exceptions: Data retained if required by law (e.g., payroll records)
Response Time: Deletion completed within 30 days of verified request
Confirmation Sent: User notified upon successful deletion

4.4 Biometric Data Deletion (Special Procedures)

Due to the sensitive nature of biometric data:

Primary Database: Facial embeddings deleted from MongoDB
File Storage: Facial images permanently deleted from storage
Backup Systems: All backups containing biometric data purged within 30 days
Cache and Logs: All cached biometric data cleared immediately
Verification: Deletion verified by automated script to ensure completeness
Documentation: Deletion logged with date, method, and verification checksum

5. Data Archival

5.1 Long-Term Retention Requirements

For data that must be retained beyond active use (e.g., employment records for 7 years):

Archival Process:

Data moved from production database to secure archive storage
Access restricted to authorized personnel only
Archives encrypted with strong encryption keys
Annual review to identify data eligible for deletion

Archive Access:

Requires administrator approval and valid business reason
All access logged and auditable
Read-only access; no modifications allowed

5.2 Archival Storage

Location: Separate secure storage infrastructure
Encryption: AES-256 encryption at rest
Access Controls: Multi-factor authentication required
Audit Logs: All archive access logged for 7 years

6. Compliance with Legal Requirements

6.1 Regulatory Frameworks

This policy complies with:

GDPR (EU): General Data Protection Regulation
CCPA (California): California Consumer Privacy Act
BIPA (Illinois): Biometric Information Privacy Act
Employment Laws: Wage/hour record retention requirements
Tax Laws: Financial and payroll record retention (7 years)
SOX (if applicable): Sarbanes-Oxley Act for public companies

6.2 Jurisdiction-Specific Adjustments

Organizations operating in specific jurisdictions may need to adjust retention periods:

Consult local employment and data protection laws
Document any deviations from this policy
Implement jurisdiction-specific retention schedules
Notify users of applicable retention periods

7. Exceptions to Retention Policy

7.1 Legal Hold

Data may be retained beyond normal retention periods if:

Subject to litigation or legal discovery
Part of ongoing investigation (internal or external)
Required by court order or subpoena
Subject to regulatory audit or inquiry

Process:

Legal hold notice issued by legal counsel
Data flagged in system to prevent deletion
Affected users notified (unless prohibited by law)
Data released from hold only after legal clearance

7.2 Security Incidents

Following a security breach or incident:

Affected data retained for investigation
Extended retention until incident fully resolved
Logs and forensic data preserved as evidence
Data retention extended as needed for legal proceedings

8. Backup and Disaster Recovery

8.1 Backup Retention

Daily Backups: Retained for 7 days
Weekly Backups: Retained for 4 weeks
Monthly Backups: Retained for 3 months
Quarterly Backups: Retained for 1 year (compliance only)

8.2 Biometric Data in Backups

Critical Consideration: Backups contain biometric data and must be handled accordingly:

Backups containing terminated employees' biometric data deleted within 30 days
Special backup rotation process for biometric-sensitive data
Encrypted backup storage with restricted access
Backup restoration requires approval for biometric data

8.3 Disaster Recovery

In disaster recovery scenarios, only necessary data restored
Expired data not restored even if present in backups
Post-recovery cleanup to remove data beyond retention periods

9. Data Minimization

9.1 Principles

We adhere to data minimization principles:

Collection Limitation: Collect only necessary data for attendance management
Purpose Limitation: Use data only for specified purposes
Storage Limitation: Retain data only as long as necessary
Access Limitation: Restrict access to authorized personnel only

9.2 Ongoing Review

Annual review of data retention needs
Quarterly review of retention policy compliance
Regular audits to identify unnecessary data collection
User feedback on data practices

10. User Rights and Data Portability

10.1 Access to Retention Information

Users can request:

What data is retained about them
How long data will be retained
When data will be deleted
Copies of retained data

10.2 Data Portability

Users can export:

Attendance records in Excel format
Personal profile information
Historical attendance summaries
Available upon request within 30 days

11. Employee Training and Awareness

All personnel with access to personal data must:

Complete annual data retention training
Understand biometric data sensitivity
Follow deletion procedures correctly
Report retention policy violations

12. Policy Review and Updates

12.1 Review Schedule

Annual policy review by legal and compliance teams
Updates for changes in applicable laws
Updates based on operational changes
User notification of significant changes

12.2 Version Control

All policy versions documented and retained
Change log maintained for audit purposes
Previous versions archived for 7 years

13. Accountability and Governance

13.1 Responsible Parties

Data Protection Officer (DPO): Overall policy compliance
System Administrators: Technical implementation of retention schedules
HR/Management: Employee data lifecycle management
Legal Counsel: Interpretation of legal requirements

13.2 Compliance Monitoring

Monthly automated compliance reports
Quarterly manual audits of data retention
Annual third-party compliance assessment
Incident reports for retention violations

14. Consequences of Non-Compliance

Failure to comply with this policy may result in:

Disciplinary action for responsible personnel
Legal liability for organization
Regulatory fines and penalties
Reputational damage
Loss of user trust

15. Contact Information

For questions about data retention:

SmartFace Attendance - Data Protection

Email: support@smartcodejunctioninfinity.in
Website: https://smartfaceattendance.in

16. Acknowledgment

By using SmartFace Attendance, you acknowledge:

You understand this Data Retention Policy
You consent to the retention periods specified
You understand your rights regarding data deletion
You will comply with organizational policies on data retention

Note: This Data Retention Policy should be read in conjunction with our Privacy Policy, Security Policy, and Terms of Service. Organizations should consult legal counsel to ensure compliance with applicable local laws and regulations.

Appendix A: Quick Reference Table

Data Type	Retention Period	Deletion Trigger
Account Data	Active + 3 years	3 years post-cancellation
Employee Info	Employment + 7 years	7 years post-termination
Biometric Data (Photos & Embeddings)	Employment only	30 days post-termination
Attendance Logs	Employment + 7 years	7 years post-termination
Authentication Tokens	Until logout	90 days inactivity
API Logs	90 days	Auto-delete
Security Audit Logs	2 years	Auto-delete
Database Backups	30 days	Rolling deletion
Verification Codes	10-30 minutes	Immediate after use
Device Data	Active + 1 year	1 year post-deactivation

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Last modified on December 13, 2025