Last updated: 10/April/2026
1. INTRODUCTION
1.1. This Data Deletion Policy explains how Onward Shift Limited (“we”, “our”, “us”) manages the deletion of personal data collected through Onward Shift offerings.
1.2. This policy supports our obligations under the UK GDPR and the Data Protection Act 2018. It outlines how long data is kept, how it is anonymised, and how you can request deletion.
2. TYPES OF DATA COVERED BY THIS POLICY
This policy applies to all personal data collected through Onward Shift services, including:
2.1. Personal Identification Data
- Name
- Email
- Phone number
- Contact information
2.2. Technical and Usage Data
- Message timestamps
- System usage patterns
2.3. Account or Registration Data
- Opt-in / opt-out records
- Consent history
3. RETENTION PERIODS
We retain personal data only for as long as necessary for service delivery, research, compliance and safety.
3.1. Long-Term Research Data (Anonymised)
- We may convert wellbeing responses into permanently anonymised datasets.
- Anonymised data cannot be linked back to you and is retained indefinitely for research, statistical reporting and service improvement.
3.2. Phone Numbers and User Identifiers
- Retained for the duration of your participation.
- Deleted within 30 days after opting out.
3.3. Consent Records
- Retained for up to 6 years to meet legal and regulatory requirements.
4. HOW DATA IS DELETED
4.1. Manual Deletion
We manually delete:
- Your identifiable wellbeing history in Google Sheets
- Your phone number and identifiers
- Any exported versions of your data
- Any backups containing your identifiable wellbeing data
4.2. Irreversible Anonymisation
After deletion or withdrawal:
- We may convert wellbeing data into anonymised form
- This process is permanent and cannot be reversed
- Anonymised data may be retained indefinitely for research purposes
4.3. Third-Party Deletion
Third-party processors delete data according to:
- Their own internal retention schedules
- Their GDPR-compliant deletion processes
5. YOUR RIGHT TO REQUEST DATA DELETION
Under UK GDPR, you may request deletion of your personal data at any time.
5.1. How to Request Deletion
Email: jo*****@*********ft.com
Subject line: “Data Deletion Request – Check-In Buddy”
Include:
- Your full name
- Phone number used for Check-In Buddy
- A clear confirmation that you want your data deleted
5.2. Timescales
We will:
- Acknowledge your request within 72 hours
- Delete identifiable data within 30 days
- Confirm deletion once completed
5.3. Exceptions
We may delay deletion if:
- Required to comply with legal obligations
- Necessary for safeguarding or risk-of-harm concerns
- Data is needed to resolve an active dispute
6. SAFEGUARDING EXCEPTION
If your responses indicate:
- Imminent risk of self-harm
- Risk of harm to others
- A safeguarding concern
We may temporarily retain relevant data beyond normal retention periods to protect your safety or comply with legal duties.
This is standard safeguarding practice.
7. CONTACT US
For questions or deletion requests:
Onward Shift Limited
Email: jo*****@*********ft.com
Website: onwardshift.com
