Retention & Deletion · Company practice
Retention follows Customer need, capped by law and stated maximums
Entrust provides the services on behalf of Customers for reasons the Customer identifies, and it relies on the Customer to tell it when the personal information is no longer needed, subject to maximum retention periods imposed by applicable laws or defined by Data Providers or by Entrust. The notice's example is the Onfido Facial Scan and Voice Recording Policy, which it says sets a maximum of three years after submission for photos/videos including audio recordings. Entrust may store personal information longer where it has a legitimate legal reason, for example a binding legal order not to destroy it.
Details
- Condition
- Customer's stated need plus maximum retention periods from law, Data Providers or Entrust
- When
- example: three years after submission for photos/videos
- Exception
- legitimate legal reason, such as a binding legal order not to destroy information
Supporting quotations
Entrust provides the Onfido Identity Services on behalf of its Customers for a variety of different reasons. Those reasons are identified by the Customer and Entrust relies on them to tell Entrust when they no longer need to store the personal information Entrust has collected on their behalf, subject to maximum retention periods imposed by applicable laws or defined by Data Providers or by Entrust.
(For example, the Onfido Facial Scan and Voice Recording Policy explains that the maximum period of time for which Entrust will retain photos/videos (including audio recordings) is three (3) years following submission of the photos/videos.
Where Entrust has a legitimate legal reason, it may store personal information for longer than described above (e.g., where it is under a binding legal order not to destroy information).
Qualifications & exceptions
- The Customer decides when it no longer needs the data.
- Caps can come from applicable law, Data Providers or Entrust.
- Longer storage is allowed for a legitimate legal reason such as a binding legal order.
Not stated here
- The Facial Scan and Voice Recording Policy is referred to but not supplied, so its full scope and exact wording are unknown here.
- The notice does not list maximum periods for the other services.
Cross-references
- qualifies (model-proposed): Facial Similarity–Video adds liveness and may capture a voiceprint — The retention section's only stated maximum is the three-year example for photos/videos including audio recordings, which qualifies how long the facial video and audio capture described in this card may be kept.