Data Retention Schedule

This schedule sets out how long ATTP retains different categories of personal data and the process by which data is deleted or anonymised when the retention period expires. It gives effect to the data minimisation and storage limitation principles of the Nigeria Data Protection Act 2023 (NDPA), section 24(1)(c) and (e), the UK General Data Protection Regulation Article 5(1)(e), and the records management principles of ISO 15489-1:2016. ATTP will not retain personal data for longer than is necessary for the purpose for which it was collected.

Participant application data (unsuccessful): two years from the date of the application decision. After this period, the record is anonymised: name, email, phone, and other identifying fields are replaced with placeholders. Programme and response data may be retained in aggregate form for impact analysis.

Participant application data (successful, programme completed): five years from the date the programme cohort ended. After this period, the record is anonymised. Programme outcome data may be retained in aggregate, non-identifiable form indefinitely.

Active participant records: retained for the duration of the programme, plus five years. Includes profile information, submissions, feedback received, and certificates issued.

Alumni records (where the participant has opted in to alumni communications): retained indefinitely until the participant withdraws consent. Participants may withdraw consent at any time by emailing info@attpglobal.com.

Financial records (donations, payments, expense claims, budgets, accounts): seven years from the end of the financial year in which the transaction took place, in accordance with the Companies and Allied Matters Act (CAMA) 2020 and Nigerian financial reporting requirements.

Safeguarding records (incident reports, disclosure records, reports to authorities): until the child to whom the record relates turns 25 years of age, or ten years from the date of the incident where the subject is an adult, whichever is later. These records may not be deleted early under any circumstances.

Staff and volunteer records (agreements, role descriptions, training records, references): for the duration of the engagement, plus six years.

Media (photographs and videos featuring identifiable individuals, whether published or unpublished): published media is retained for the duration of the consent given. Unpublished raw media is deleted within two years of capture. Where consent is withdrawn for previously published media, ATTP will remove the media from its platforms where practically possible.

Correspondence (emails, form submissions, enquiries): two years from the date of receipt, unless the correspondence is linked to a longer-lived record (such as a safeguarding report, a grant application, or a financial transaction), in which case it is retained for the same period as the primary record.

Website analytics (non-identifiable aggregate data): twelve months from the date of collection, after which data is permanently deleted from all ATTP systems and analytics platforms.

Newsletter and broadcast contact data (for individuals who have consented to receive communications): retained indefinitely until the individual unsubscribes or withdraws consent. Unsubscribe requests are actioned within five working days.

At the end of each retention period, personal data will be:

(a) Permanently deleted from all ATTP systems, including backups, within 30 days of the retention period expiry date; or (b) Anonymised so that the individual is no longer identifiable, where the underlying aggregate data has ongoing value.

"Permanently deleted" means the data cannot be recovered through normal technical means. Where cloud storage providers are used, ATTP will confirm deletion with the provider in writing.

ATTP may in limited circumstances collect special category data as defined under the NDPA 2023 and GDPR (including health information, disability status, or religious belief where relevant to programme adjustments). Such data will be retained for no longer than is strictly necessary for the specific purpose for which it was collected, and will be deleted promptly when that purpose is fulfilled, regardless of the general retention periods above.

Any individual may request a copy of the personal data ATTP holds about them, or request its deletion, by submitting a Data Subject Access Request via attpglobal.com/data-request. ATTP will respond within 30 days of the verified request being received. Where ATTP is required to retain data by law (for example, financial records or safeguarding records), it will explain this to the requester and describe what can and cannot be deleted.

This schedule will be reviewed annually by the Founder alongside the Data Protection Policy (Internal) to ensure it remains consistent with current Nigerian law, any applicable international frameworks, and ATTP's evolving data processing activities.