CPQ-DATA-2026-v1.0 · CPQ™ INSTITUTIONAL STANDARD
CPQ Data Protection & Records Retention Policy
Retention and deletion periods and access rights for credentialing, complaint and research records.
External Review Draftv1.0Issued 2026-08-16Review 2026-11-16
External Review DraftNumeric or procedural requirements not fixed in the original source materials remain proposed CPQ™ policy until formally adopted.
1. Purpose & Data Minimisation
CPQ collects only data necessary to deliver services, evidence entitlement or meet legal compliance, and separates identity data from aggregated research data where practicable.
2. Retention Periods
| Record | Period | Action |
|---|---|---|
| Approved credential application | Credential term + 7 years | Archive then remove detailed evidence while retaining core registry record |
| Declined application | 3 years | Delete unless an appeal is active |
| Complaint/ethical review | 10 years | Restricted archive then delete sensitive personal data |
| Assessment recordings | 2 years | Delete unless linked to appeal/investigation |
| Raw research data | 5 years | Fully anonymise before further use |
3. Access & Deletion
Individuals may request access, correction or deletion. Deletion may be partly declined for legal obligations, audit or active appeals/complaints, with reasons documented. The operational target for access requests is 30 days.
4. Security & v111 Pre-Activation Addendum
- Encryption and role-based access.
- Access logs for complaint and assessment files.
- Annual security review of registry-linked databases.
Proposed pre-activation addendum: appoint a privacy contact, maintain a data-incident/breach procedure, and document cross-border transfer controls according to applicable law. Legal review by jurisdiction remains required.
CPQ™ · Institutional Review Centre