Data Retention and Disposal Policy

• Document owner: Oscar Ramos
• Approved by: Eli Johnson, Product Manager
• Version: 1.0
• Approved date: 9/21/2026
• Next review: 9/21/2027
• Applies to: Founders, Co-Founders, Designers, Head of Education Partnerships, and Software Developers

1. Purpose

To ensure Ladderly Learning keeps data only as long as it has a legitimate business, legal, or contractual reason to, and disposes of it securely afterward. This is central to our FERPA duty (we return or delete student data when the school’s contract ends and don’t hold it indefinitely), supports data minimization, and satisfies SOC 2 confidentiality and secure-disposal criteria.

2. Principles

• Minimize. Collect and retain only the data we actually need.
• Time-bound. Every category of data has a defined retention period.
• Contract governs student data. For student education records, our Contract with each school controls — we act on the school’s instructions and never keep student data longer than the contract allows.
• Secure disposal. When retention ends, data is destroyed so it cannot be recovered.

3. Student data (special handling)

Because we are a FERPA “school official,” student education records get the strictest treatment:

• We hold student data only for the purpose and duration in our contract with the school.
• We do not use it for any other purpose and do not sell it.
• At contract termination (or on the school’s request), we return and/or securely delete all student data and confirm deletion in writing if requested.
• This extends to copies in backups and with any subprocessors

4. Retention schedule

5. Secure disposal methods

Disposal must make data unrecoverable, matched to the medium:

• Cloud/database records: permanent deletion via the application/database; ensure the data is purged from backups on the defined cycle.
• Files/documents: permanent deletion (empty trash/recycle); for Restricted data use secure-delete where available.
• Paper: cross-cut shred any printed Restricted/Confidential data.

6. Responsibilities

• Security Officer maintains this schedule, oversees student-data deletion at contract end, and keeps disposal records.
• All personnel delete drafts, exports, and copies of Restricted data when no longer needed, and never store student data in unapproved locations (personal drives, personal email, unmanaged tools).

7. Records of disposal

For Restricted data — especially student-data deletions at contract end — keep a record of what was deleted, when, by whom, and confirmation to the school. Retain these records as SOC 2 and Contract evidence. These records will be recorded and kept in our google drive.

8. Enforcement & exceptions

Violations may result in disciplinary action. Exceptions (e.g., a longer retention need) require documented approval from the Security Officer, and never override a legal hold or a shorter contractual limit.

9. Review

Reviewed and re-approved at least annually and upon significant change (new data types, new contractual requirements, new laws).