How EduSwap retains, deletes and manages platform data
1. Purpose
This Data Retention and Deletion Policy explains how EduSwap Pty Ltd manages the storage, retention, archival, anonymisation and disposal of data collected through the EduSwap platform.
This Policy is designed to align with the Australian Privacy Principles, the Privacy Act 1988 (Cth), relevant state privacy requirements, the Notifiable Data Breaches Scheme, and Department of Education privacy and security expectations.
EduSwap retains data only for as long as reasonably necessary to provide services, meet legal or operational obligations, support audit, billing and dispute-resolution requirements, and protect platform integrity.
This Policy should be read together with EduSwap’s Privacy Policy, Terms of Service, Security and Infrastructure Statement, and other platform policies.
2. Scope
This Policy applies to schools, school staff, authorised representatives and other approved users of EduSwap.
It covers personal information, school account data, listings, transactions, audit logs, metadata, analytics, backups and archived information collected or generated through the platform.
EduSwap is not intended to collect, store or process student data.
3. Principles of data retention
Data minimisation: EduSwap aims to collect and store only the information needed to operate the platform safely and effectively.
Purpose limitation: data is retained for legitimate operational, security, legal, audit or service-related reasons.
School control: authorised schools may request access, correction or deletion of relevant data, subject to legal, security and operational requirements.
Secure lifecycle management: data is stored, archived, retained and deleted using appropriate safeguards.
Transparency: schools may request information about the categories of information held and how retention rules apply.
4. Retention periods
User account data, including name, school email, role, authentication details and account metadata, is generally retained for the duration of the account and removed within 30 days of account termination unless retention is required for legal, audit, security or dispute-resolution purposes.
School account data, including school name, contact details, subscription records and settings, is generally retained while the school maintains an account and may be removed within 30 days of an authorised request or after a prolonged period of inactivity.
Listing data, including item details, images, descriptions and listing activity, is generally retained while active, then archived. Archived listings may be removed after 24 months unless needed for fraud prevention, audit, legal or dispute-resolution purposes.
Transaction data, including swaps, sales, rentals, leases, communication records, timestamps and values, may be retained for up to 5 years to support financial accountability, auditability, fraud prevention and school record-keeping needs.
Security and audit logs, including login events, IP addresses, admin actions and suspicious activity records, may be retained for up to 24 months unless a longer period is reasonably required for investigation, security or legal reasons.
Analytics and metadata are anonymised or aggregated where reasonably practicable. Identifiable analytics are intended not to be retained longer than reasonably necessary for platform reliability, security and improvement.
Encrypted backups are generally retained for up to 90 days and then overwritten or replaced through standard backup lifecycle processes.
5. Data deletion process
EduSwap follows a controlled process for assessing and actioning deletion requests.
Where a school requests deletion, EduSwap may verify the requester’s authority before deactivating or deleting relevant records.
Personal information is intended to be deleted, de-identified or otherwise handled within 30 days of a valid request, unless a longer period is required for legal, audit, security, billing, fraud-prevention or dispute-resolution purposes.
Where full deletion is not immediately possible because data exists in encrypted backups, the information will be handled through the normal backup expiry and overwrite cycle.
6. Inactive accounts
EduSwap may review inactive accounts as part of routine data minimisation and platform integrity practices.
Inactive accounts may be flagged after a prolonged period of inactivity.
Where reasonably practicable, EduSwap may notify the relevant school before deletion or deactivation occurs.
Accounts that remain inactive may be deleted, de-identified or restricted in line with this Policy and applicable obligations.
7. Mandatory deletion
EduSwap may delete, de-identify, restrict or archive data where required by law, required by an authorised Department of Education process, necessary for risk mitigation or security purposes, or requested by an authorised school contact.
Deletion decisions may take into account financial record obligations, audit requirements, security investigations, fraud-prevention needs and unresolved platform disputes.
8. Data anonymisation
After deletion or account closure, EduSwap may retain anonymised or aggregated data for reporting, system analytics, platform improvement and sector-level insights.
Anonymised data is intended to contain no information that reasonably identifies a school staff member or individual user.
Where data cannot be reliably anonymised, EduSwap will assess whether it should be deleted, further de-identified, restricted or retained for a lawful purpose.
9. Secure destruction methods
EduSwap uses appropriate technical and operational methods to support secure deletion and destruction of data.
Methods may include cryptographic erasure, secure overwrite processes, encryption key destruction, removal of index references, deletion from active systems, and expiry through encrypted backup lifecycle controls.
Secure destruction practices are intended to reduce the risk of unauthorised recovery or misuse of data that is no longer required.
10. Data access rights
Authorised schools may request a summary of data held about their users, a copy of relevant retained records, correction of inaccurate information, or confirmation of deletion where available.
EduSwap aims to respond to valid access, correction and deletion requests within 30 days, or sooner where required for Department assessment, legal obligations or urgent privacy matters.
Requests may be subject to identity and authority checks before information is released or changed.
11. Department of Education alignment
EduSwap’s retention and deletion practices are intended to support Victorian and NSW Department of Education privacy, cloud, information security and records-management expectations.
EduSwap may participate in privacy reviews, ICT onboarding assessments, vendor compliance checks and audits where reasonably requested by schools or Departments of Education.
Where Department guidance changes, EduSwap may update retention and deletion practices to remain aligned with relevant expectations.
12. Changes to this policy
EduSwap may update this Policy from time to time to reflect platform changes, legal requirements, operational learnings or Department expectations.
Updated versions will display a revised last updated date.
Continued use of EduSwap after an update indicates acceptance of the revised Policy.
13. Contact information
For enquiries, access requests, correction requests or deletion requests, contact EduSwap Pty Ltd.
Email: support@eduswap.com.au