Stonehill Consultancy: Data Retention Schedule
This table defines the lifecycle of information across the enterprise. Information will be securely deleted or anonymized once the Maximum Retention Period is reached, unless a “Legal Hold” (e.g., active litigation or audit) is in place.
| Data Category | Specific Record Types | Retention Period | Regulatory Rationale |
| Corporate & Finance | Tax returns, audit reports, general ledgers, project financing contracts. | 7 Years | IRS / Federal Statute of Limitations |
| KYC / AML Records (If required by Funding Source) | Background checks, ID copies, beneficial ownership declarations. | 5 Years | Bank Secrecy Act (BSA) / AML Best Practices |
| Student Records (PII) | Enrollment forms, grades, disciplinary records, attendance. | Enrollment + 7 Years | NY Education Law 2-d / FERPA |
| E-commerce Data | Transaction history, invoices, shipping logs (Every Critter). | 7 Years | PCI-DSS & Sales Tax Compliance |
| Professional Contacts (Included in Contacts General Additions) | CRM leads, inquiry emails, consultancy outreach. | 3 Years | Business Utility / GDPR “Right to be Forgotten” |
| AI Interaction Logs (If AI is Implemented) | Technical prompts, AI feedback, hardware diagnostic logs. | 24 Months | 2026 AI Ethics & Transparency Standards |
| Employment Records | Payroll, background checks for staff, performance reviews. | 7 Years | FLSA / EEOC Requirements |
Implementation Protocol
1. The “Secure Disposal” Requirement
- Digital Data: Must be overwritten using industry-standard wiping software or permanent deletion from encrypted cloud backups.
- Physical Data: Any physical KYC or student files must be cross-cut shredded.
2. Anonymization Exception
Stonehill reserves the right to retain Anonymized Data indefinitely for the purpose of training AI models within the Human AI Co-Op or AIBF. This data is stripped of all “Identifiers” so that the information can no longer be linked to a specific individual.
3. Linking to the Master Policy
Linked this to Master Document, added the following clause to Section 5 (Data Retention) of the Privacy Policy:
“For a detailed breakdown of how long specific categories of data are stored, please refer to the Stonehill Data Retention Schedule (v2026.1), which is incorporated herein by reference.”