Preamble
The Guaranty Support Incorporated (GSI) provides the UDS Data Mapper free of charge to liquidators to assist with the production, validation, and distribution of UDS, document images, and other insolvency related data (collectively referred to as “The Data”) to our member Guaranty Funds. The Data Mapper provides a secure and uniform way for liquidators to send “The Data” to Guaranty Funds.
Purpose
The purpose of this policy is to minimize the potential exposure of personal data to the risk of accidental loss, interception, or disclosure to unauthorized persons by establishing the maximum period of time The Data may remain on GSI infrastructure, servers, file systems, databases, etc.
Data covered by this policy
This policy applies to all data stored in the UDS Data Mapper database, any file system directories that contain claims images that the Data Mapper code interacts with, and any other non-SUDS file systems to which the UDS Data Mapper writes and/or interacts.
Retention Period
Barring extenuating circumstances, The Data is subject to automatic deletion 12 months after it was first loaded. At intervals of 6 and 9 months, automated notification emails will be sent to the liquidator with a summary of The Data that will be deleted when the retention period expires. At any time during the retention period, the liquidator has access to bulk and selective record deletion tools. If at any time it is determined that the liquidator does not need to maintain The Data within the Data Mapper, The Data should be promptly deleted using these tools or by contacting GSI staff.
Extenuating Circumstances
If it is determined that the liquidator is unable and/or unwilling to maintain The Data after the 12 month period, an exception to the retention period may be granted after consulting with GSI senior management. If an extension is granted, GSI shall consult with the liquidator in intervals of not more than six months to determine when the data can be deleted.
Automated process
Data greater than 12 months old will be automatically deleted. Final notification to the liquidator is provided upon deletion.
Notification
Data Mapper users will be notified of the retention policy in writing after having their Data Mapper accounts activated.
Responsibility for implementation of retention policy
GSI’s Chief Information Officer shall be responsible for implementation and maintenance of this policy.