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Legal · B2B

Data Retention Policy

How long PlumbMate keeps the records a college creates in it, who decides that, and what the platform does when a record reaches the end of its retention period. Written to sit alongside the Data Processing Agreement, which governs the processing itself.

Version 1.0  ·  September 2026  ·  UK GDPR Article 5(1)(e) — storage limitation
The college decides, not PlumbMate. Under the DPA the college is the Data Controller and Holwell Educational Services Ltd is the Data Processor. How long assessment and quality assurance records are kept is the controller's decision. PlumbMate holds a period the college sets, tells you when a record passes it, and deletes nothing on its own.
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1. What this policy covers

1.1 This policy covers records a college creates inside PlumbMate: IQA sampling plans and their rationales, sampled cell decisions and feedback, standardisation agendas and minutes, assessor observation records, countersigning records, staff credential records and CPD dates, EQA visit records, and the learner names and email addresses attached to any of them.

1.2 It does not cover the learner's own assessment evidence. Portfolios, task manuals and marked work are held by the college, not by PlumbMate, and are governed by the college's own storage procedure and by the awarding organisation's requirements.

1.3 Learner progress data — quiz results, revision activity and study records — is covered by the Privacy Policy and by clause 4.4 of the DPA.

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2. The obligations a college is under

2.1 PlumbMate does not set these. They come from the awarding organisation, the regulator and, for apprenticeships, the funding body. A college should confirm the current version of each rather than rely on this summary.

SourceWhat it requires
City & Guilds Centre Manual Centre documents and records held from registration and retained for a minimum of three years following certification. Named explicitly: IQA sampling plans, records and feedback reports; who internally quality assured what and when; the sample selected and its rationale; standardisation meetings; assessor and IQA competence records.
C&G qualification handbooks and assessor guides Learner evidence held at least until the next external sampling activity; candidate assessment records for three years after certification.
Apprenticeship funding rules Providers delivering funded apprenticeships are required to keep evidence for substantially longer than three years. Colleges should check the period in the funding rules current at the time, as it has changed between versions and is the longest obligation most providers are under.
UK GDPR Article 5(1)(e) Personal data kept no longer than is necessary for the purpose. A retention period that is longer than every obligation above needs a reason.
The college's own policy Where a college has its own records retention procedure, that is the one PlumbMate should be set to follow.
Three years is a floor, not a target. An appeal, a malpractice investigation or a regulatory audit can reach back further than the minimum, and a record destroyed on the last permitted day is a record that is not there when it is asked for. The period a college chooses should be the longest obligation it is under, plus room for the year in which a query might arrive.
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3. The period, and who sets it

3.1 Each college sets its own retention period in the IQA module. PlumbMate offers three, five or six years, and defaults to six.

3.2 Six is the default because it is the longest of the periods a college delivering funded apprenticeships is typically under, and because a default that is too short deletes something somebody needed while a default that is too long is a decision the college can correct in one click.

3.3 The period runs from the end of the academic year the plan belongs to, not from the date the plan was created or last edited. A plan for 2026/27 reaches the end of a six-year period on 31 July 2033.

3.4 Changing the period does not delete anything. It changes which records are flagged.

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4. What happens when a record passes its period

4.1 Nothing is deleted automatically. PlumbMate does not delete a college's records on a timer, at the end of a period, or in a scheduled job.

4.2 A plan past the retention period is marked past retention in the archive, with the date it passed and a summary of what it holds — the group, the qualification, how many learners are named in it, and how many sampled decisions it records.

4.3 An authorised user may export the plan before deleting it, as a structured JSON file, so the record can be kept in the college's own archive if it is still needed.

4.4 Deletion is carried out by an authorised user, who is shown exactly what will be removed and must confirm it. Deletion is permanent and cannot be undone from within PlumbMate.

4.5 Records inside the retention period are not offered for deletion through this mechanism. A college wanting a specific record removed earlier — for example on a data subject's erasure request — should follow section 8 of the DPA.

Why there is no automatic deletion. Three reasons, and any one of them would be enough. The DPA commits to retaining data for the duration of the subscription, so a timer deleting inside it would contradict an agreement colleges have signed. Article 28 says a processor acts only on documented instructions, and a period chosen by the processor is not an instruction from the controller. And a record destroyed the week before an appeal, a funding audit or an EQA query is the college's problem, caused by a decision the college did not make.
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5. Who may delete

5.1 Only a signed-in user with the IQA or administrator role at that college may delete a plan past its retention period. Assessors and tutors cannot.

5.2 PlumbMate does not delete a college's records on its own initiative, on request from a third party, or at the request of an individual learner. A learner exercising the right to erasure should contact the college, which will instruct us under section 8 of the DPA.

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6. End of subscription

6.1 This policy governs records during an active subscription. What happens when a subscription ends is set out in clause 4.4 and section 12 of the DPA: data is retained for a maximum of 90 days to allow final exports or queries, and is then permanently deleted.

6.2 A college that needs its IQA records beyond that point should export them during the 90-day window. The DPA provides for return in a structured, machine-readable format on request.

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7. Questions

A college's Data Protection Officer or quality manager can raise anything in this policy with us at info@plumbmatemastery.co.uk. Where a college's own retention procedure differs from what PlumbMate offers, tell us — the periods available are a product decision and can change.