Data Retention & Deletion Policy

Effective Date: October 25, 2026 • Supervising Authority: Nigeria Data Protection Commission (NDPC) • Version: 2026.1 (Pilot Ready)

STATUTORY STORAGE LIMITATION DIRECTIVE:
Pursuant to Section 24(1)(d) of the Nigeria Data Protection Act (NDPA) 2023, personal and corporate information must not be retained for longer than is necessary to achieve the specific purposes for which it was collected. This Policy defines the binding retention periods and cryptographic disposal protocols for identity documents, project records, financial ledgers, and user accounts.

Policy Table of Contents

1. Statutory Framework & Objectives 2. Master Data Retention Schedule 3. Identity Documents (NIN, Passports, CAC) 4. Project Records, CAD & Milestone Deliverables 5. Financial & FIRS Tax Invoicing Records 6. Inactive Accounts & Dormancy Lifecycle 7. Cryptographic Deletion Protocols 8. Statutory Legal Holds & Litigation Holds 9. Right to Erasure (NDPA Sec 34) Procedures

1. Statutory Framework & Objectives

This Policy harmonizes the storage limitation principle of the NDPA 2023 with mandatory Nigerian statutory retention requirements, including:

Nigeria Data Protection Act (NDPA) 2023: Section 24(1)(d) storage limitation and Section 34 Right to Erasure.
Companies Income Tax Act (CITA Cap C21 LFN 2004): Mandatory 6-year retention of corporate financial books and commercial invoices.
Money Laundering (Prevention and Prohibition) Act 2022: Mandatory 5-to-6 year retention of customer transaction records and KYC verification hashes.
Evidence Act 2011 (Section 84): Maintaining immutable electronic audit trails for commercial contract enforceability.

2. Master Data Retention Schedule

The following schedule governs the retention and automated disposal lifecycle across all Collekt environments:

Data Classification	Primary Retention Period	Statutory Trigger	Disposal Protocol
Raw Identity Scans (NIN, Passport)	30 Days following verification approval	Completion of identity validation against NIMC	Automated file purge from cloud storage bucket; zero disk remnants.
Verification Status & Audit Hashes	6 Years following account termination	Money Laundering (Prevention) Act 2022	Database cryptographic record archive; WORM retention.
Project Scopes, Bids & Deliverables	Contract Duration + 3 Years post-sign-off	Commercial dispute & warranty limitation period	Cold storage encryption archive; bucket tombstoning upon request.
In-App Messages & Chat Discussions	3 Years following contract sign-off	Evidence Act 2011 electronic evidence standard	Cascade purge of message threads; unrecoverable redaction.
Financial Ledgers & Tax Invoices	6 Years from transaction settlement date	CITA 2004 & FIRS Withholding Tax Regulations 2024	Immutable financial ledger archive; hard-locked against deletion.
Inactive / Dormant User Accounts	24 Months Warning • 36 Months Purge	Continuous non-login dormancy	Cascade deletion of profile record, credentials, and telemetry.
System Telemetry & Audit Logs	7 Years	ISACA ITAF & CBN Cybersecurity Framework	Database trigger-locked WORM archive purge upon expiration.

3. Identity Documents & Shield Verification Records

To eliminate high-risk data stores of citizen identification credentials:

Raw Document Scans: Uploaded images of National Identity slips, voter cards, or international passports reside in a private quarantined storage bucket. Within 30 days of verification approval by our compliance team, raw image files are permanently purged.
Verification Hashes: Only an immutable cryptographic proof (e.g. NIN_VERIFIED_SHA256), timestamp, and compliance auditor ID are retained in the database to satisfy CBN and NFIU anti-money laundering audit requirements.

4. Project Records, CAD Schematics & Deliverables

Intellectual Property Transfer: Once the Corporate Client approves the final milestone and escrow funds disburse, ownership of deliverables vests in the Client pursuant to Section 12 of the Terms of Service.
Archive Period: Project specifications, CAD drawings, and milestone attachments are preserved in active storage for three (3) years post-completion to support engineering defect warranties and commercial arbitration under the *Arbitration and Mediation Act 2023*.
User-Initiated Purge: Both parties may mutually request early deletion of proprietary CAD files upon providing written waiver of warranty claims.

5. Financial & FIRS Tax Invoicing Records

Collekt is legally prohibited from executing early deletion of financial transaction records. Under Section 63 of the Companies Income Tax Act (CITA) and FIRS regulations:

All dedicated virtual NUBAN transaction logs, escrow deposits, and bank payout receipts must be preserved for six (6) full calendar years.
Serialized FIRS Electronic Tax Invoices itemizing 7.5% VAT and 5% Withholding Tax (WHT) deductions remain permanently locked against client-side or administrative modification.

6. Inactive Accounts & Dormancy Lifecycle

Accounts exhibiting complete absence of logins or transactions follow a structured dormancy lifecycle:

12 Months Inactivity: Account receives an automated security notice prompting the user to confirm active status.
24 Months Inactivity: Account is designated "Dormant". Profile is hidden from public marketplace search queries. A final 90-day grace period notice is dispatched.
36 Months Inactivity: In the absence of active escrow balances or unresolved disputes, the account undergoes automated cascade purge and anonymization.

7. Cryptographic Deletion Protocols

Deletion at Collekt implies permanent, unrecoverable destruction through verified methods:

Crypto-Shredding: Deleting the unique symmetric encryption key (AES-256) protecting specific user buckets, rendering encrypted files mathematically indecipherable.
Database Cascade Deletion: Foreign-key cascade procedures in PostgreSQL purge user records across dependent tables, removing personal identifiers.
Zero Backup Persistence: Backups cycle through a 30-day rolling rotation, ensuring purged records automatically expire from disaster recovery snapshots within 30 days.

8. Statutory Legal Holds & Litigation Holds

The normal retention and deletion schedule is immediately suspended ("Legal Hold") upon:

Receipt of a valid judicial subpoena, court order, or formal request from the Nigeria Data Protection Commission (NDPC), EFCC, or Nigerian Police Force.
Commencement of formal commercial arbitration or litigation regarding disputed milestone deliverables or payment fraud.

9. Right to Erasure (NDPA Sec 34) Self-Service Procedures

Users can trigger immediate account deletion by navigating to Profile → Account Settings → Danger Zone → Request Account Erasure. Upon submission:

Profile details, active proposals, and resume files are purged within fourteen (14) business days.
Users receive a digital Certificate of Data Erasure confirming successful execution under NDPA Section 34.