Data Retention Policy
Applies to: Defined Learning, Defined Careers, Defined @ Work and all related web applications, APIs, and integrations (collectively, the "Services") Effective date: 7/1/2026
This policy explains what data Defined Learning collects through the Services, how long we keep it, and how it is deleted. It is written for school and district administrators, teachers, and parents, and it supplements our Terms of Service and Privacy Policy. Where a signed Data Privacy Agreement (DPA) with a school or district sets different terms, the DPA controls.
1. Our approach
We keep data only as long as it is needed to deliver the Services, meet our obligations to schools, and satisfy legal requirements. We do not keep student data longer than necessary, we do not sell it, and we do not use it to build profiles for non-educational purposes.
Defined Learning operates as a school official under FERPA and as a service provider under state student privacy laws (including SOPIPA and similar statutes). Schools and districts own the student data they and their students create in the Services. We process it on their behalf and delete it on their instruction or at the end of the relationship, as described below.
2. Categories of data and retention periods
| Data category | Examples | Retained while | Deleted / de-identified |
|---|---|---|---|
| Student account data | Name, grade level, school, class enrollment, login credentials, roster ID from Clever/ClassLink | Account is active and the school's subscription is current | Within [90] days after the school's subscription ends, or sooner on written request |
| Student work product | Project submissions, uploaded files, written responses, portfolio artifacts, self-assessments, career interest survey results | Account is active and the school's subscription is current | Same as student account data |
| Teacher / administrator account data | Name, school email, role, school/district assignment, classes managed | Account is active and the school's subscription is current | Within [90] days after the subscription ends, or on request |
| Grading, feedback, and progress data | Rubric scores, teacher comments, completion status, badges earned | Account is active and the school's subscription is current | Same as student account data |
| Rostering and integration data | Synced records from Clever, ClassLink, or manual CSV import; LTI launch context | Integration is connected | Removed on the next sync after a record is removed at the source, and fully deleted with the school's data at subscription end |
| Usage and analytics data | Pages viewed, features used, time on task, device/browser type | Up to [24] months in identifiable form | De-identified or aggregated after [24] months; aggregated data with no personal information may be kept indefinitely for product improvement and research |
| AI feature data | Prompts and responses generated by AI-assisted features (e.g., feedback suggestions, project scaffolding) | Same as the related student or teacher record | Deleted with the associated account data. AI inputs and outputs are not used to train third-party models. |
| Support communications | Help desk tickets, emails, chat transcripts (including this HelpScout system) | [3] years from the last message | Deleted after the retention period |
| Billing and contract records | Purchase orders, invoices, DPAs, signed agreements | Duration of the relationship plus [7] years | Deleted after the period required by tax, accounting, and audit rules |
| Security and access logs | Login events, IP addresses, authentication attempts, admin actions | [12] months | Automatically purged on a rolling basis |
| Backups | Encrypted database and file snapshots | Rolling [30]-day window | Backups expire automatically; data deleted from production is removed from backups within [30] days |
Bracketed values reflect our current standard periods and are confirmed in each school's DPA.
3. Deletion at the end of a subscription
When a school or district's subscription ends:
- Grace period. Accounts are deactivated but data is preserved for [90] days so the school can renew or export its data.
- Export. During the grace period, administrators can request a full export of student work product and progress data in a standard format (CSV, PDF, or ZIP of original files).
- Deletion. After the grace period, all student and staff personal information is permanently deleted from production systems. Backups containing that data expire within the backup window described above.
- Confirmation. On request, we will provide written confirmation that deletion is complete.
A school can shorten the grace period by submitting a written deletion request at any time.
4. Deletion on request
Schools and districts may request deletion of any or all of their data at any time by contacting [privacy@definedlearning.com]. We complete verified requests within [30] days and confirm in writing.
Parents and eligible students should direct requests to review, correct, or delete a student's data to their school, which controls the student's education records. We will act on the school's instruction. If a parent contacts us directly, we will acknowledge the request and coordinate with the school.
Individual teachers who leave a school should ask their administrator to deactivate the account. If a teacher created a personal account outside a school subscription, they may request deletion directly.
Some data may be retained after a deletion request where the law requires it (for example, billing records or a legal hold), or where it has been fully de-identified.
5. Inactive accounts
Accounts with no login activity for [24] consecutive months under an otherwise active subscription are flagged to the school's administrator. If the school takes no action within [60] days, the account is deactivated and its data is handled as described in Section 3.
6. De-identified data
We may retain data that has been de-identified so that it cannot reasonably be linked to any student, teacher, or school. We use this data to improve curriculum, measure program effectiveness, and support research. We contractually prohibit anyone we share it with from attempting to re-identify it.
7. Data security during retention
Data is stored in US-EAST on infrastructure operated by AWS, encrypted at rest and in transit. Access is limited to employees and contractors with a need to know, protected by multi-factor authentication, and logged. Deletion is performed using methods that prevent recovery, and decommissioned storage media are securely wiped or destroyed.
8. Legal holds and exceptions
If we receive a valid legal request, subpoena, or notice of pending litigation, we may suspend deletion of relevant data until the matter is resolved. We will notify the affected school unless legally prohibited from doing so.
9. Changes to this policy
We review this policy at least annually and whenever our Services or applicable law change materially. Schools with active subscriptions will be notified of material changes at least [30] days before they take effect.
10. Contact
Questions about this policy or data deletion requests:
Defined Learning Privacy Team Email: [privacy@definedlearning.com]