Doc 17 — Document Retention / Records Notice
| Document | Doc 17 — Document Retention / Records Notice (the "Retention Notice") |
| Version | 17-document-retention-notice-2026-08 (in force on publication) |
| Party / entity | DPW Pte. Ltd. (UEN 202017982R), 247B Victoria St, Singapore 188033 ("DPW", "we", "us") |
| Audience | Customers, Users, Participating Firms; referenced by Doc 04 — Privacy Notice, Doc 05 — Data Processing Addendum and Doc 19 — DPO / Data Subject Request Procedure |
1. Purpose
1.1 This Notice (the "Retention Notice") explains how long records and personal data are kept on the Platform and what happens when a retention period ends. It reconciles two duties that pull in opposite directions: the PDPA Retention Limitation Obligation (section 25 — cease to retain, or anonymise, personal data once it is no longer necessary for the purpose or a legal or business purpose) and the statutory record-keeping duties that apply to regulated corporate services, in particular client-due-diligence ("CDD") record retention under the Corporate Service Providers Act 2024.
1.2 Where a Participating Firm is the organisation responsible for records (notably CDD and engagement records), retention is the Firm's legal obligation; the Platform supports it as the Firm's data intermediary (see Doc 05 — Data Processing Addendum, clauses 3 and 7).
2. Retention classes
2.1 Records on the Platform are assigned to one of the following classes. The period runs from the trigger stated for the class, not from the date of collection.
| Class | Typical records | Retention period | Trigger | Responsible party |
|---|---|---|---|---|
| CDD / AML | Identity documents, verification records, screening results, risk assessments, transaction and engagement records required under AML/CFT rules | Minimum 5 years (CSP Act 2024, s 17(5)) | After the Firm ceases to provide services to the relevant customer | The Participating Firm (its statutory obligation; the Platform supports retention on the Firm's instruction) |
| STATUTORY | Records required by other Singapore law (e.g. accounting, tax, corporate records) | 7 years [CQ-RET-1 — period to be confirmed by counsel] | End of the relevant financial year / engagement, per the governing statute | The party the statute binds (Firm or Customer); Platform supports |
| CONTRACTUAL | Signed engagements, service orders, authorisations, correspondence evidencing contractual rights | 6 years, aligned to the limitation period [CQ-RET-1 — period to be confirmed by counsel] | End of the contract or last performance | DPW and/or the Firm, per the relevant contract |
| OPERATIONAL | Workflow records, case activity, support records, non-statutory communications | 2 years | Closure of the case or account activity concerned | DPW |
| TRANSIENT | Drafts, temporary processing artefacts, expired sessions, unconverted leads | 1 year | Creation or last activity | DPW |
2.2 Where a record falls into more than one class, the longest applicable period governs.
2.3 Audit / evidence ledger. The append-only audit ledger (see Doc 13 — Security / Data-Protection Schedule, clause 3.6) evidences approvals, access and filings-related actions. Ledger entries relating to a record are retained at least as long as the underlying record's class, and entries evidencing regulated decisions (CDD approvals, filing authorisations) follow the CDD/AML or STATUTORY class as applicable.
3. End-of-retention handling — honest description
3.1 When a retention period ends, the record becomes due for review, and on review is deleted or anonymised unless a legal hold (clause 7) or a longer overlapping class applies.
3.2 What actually happens today. Erasure on the Platform is currently request-driven: deletion and anonymisation run when an erasure request or a documented instruction is executed, not on an automatic timer. There is no automatic time-based purge. DPW's commitment is therefore a periodic scheduled review of records past their retention period, followed by deletion or anonymisation of those that no longer need to be kept — not automatic deletion at the moment a period expires. This Notice deliberately does not promise automation that does not exist.
3.3 Data deleted from production may persist in routine backups until the ordinary backup cycle completes; backups are used for disaster recovery only (Doc 05, clause 10.2(c); Doc 13, clause 6).
4. Erasure requests and statutory carve-outs
4.1 Individuals may ask for personal data to be deleted; the procedure is in Doc 19 — DPO / Data Subject Request Procedure. The PDPA does not create an absolute right to erasure, and statutory retention duties prevail over an erasure request (the precise lawful basis for each refusal category is a counsel item, CQ-RET-2).
4.2 CDD/AML records cannot be erased during the statutory period. Records a Participating Firm must keep under the CSP Act 2024 or AML/CFT requirements are retained for the full statutory period notwithstanding an erasure request or deletion instruction, with access restricted to compliance purposes (Doc 05, clause 10.3).
4.3 What is redacted versus retained. Where an erasure request is partly accepted: personal data with no remaining legal or business purpose (for example marketing preferences, optional profile data, non-statutory communications) is deleted or anonymised; data within a statutory class is retained but flagged as restricted, excluded from operational use, and used only for compliance, audit, defence of legal claims or regulator requests. The requester is told which parts were erased and which were retained and why (Doc 19).
5. Customer exit
5.1 On expiry or termination, Controller Data remains available for export in a commonly used electronic format for 30 days (Doc 05, clause 10.1; a Participating Firm's unrestricted CDD export right under Doc 05 clause 7.3 continues during that window).
5.2 After the export window, records are handled per their classes in clause 2: statutory and CDD/AML classes are retained for their remaining periods (on the Firm's instruction where the Firm is responsible), and the remainder is deleted or anonymised through the scheduled-review process in clause 3.
6. Where records live
6.1 Records are held on managed database and private document-storage infrastructure, with primary data stored in Singapore-region infrastructure and certain functions performed by overseas providers. This Notice describes providers only by function; the named providers, their locations and the applicable overseas-transfer mechanisms are listed in the Subprocessor and Service Provider Notice (see Doc 06 — Subprocessor and Service Provider Notice). DPW does not represent that all data stays in Singapore.
7. Legal holds
7.1 Where litigation, a regulatory investigation, an incident investigation or a lawful demand is pending or reasonably anticipated, affected records are placed on legal hold: retention periods are suspended, deletion and anonymisation are paused for those records, and the hold is released only when the underlying matter concludes. Legal holds prevail over every retention class and over erasure requests, to the extent the law allows.
8. Review of this Notice
8.1 This Notice and the class assignments in clause 2 are reviewed at least annually and whenever a relevant statute, regulatory guidance or Platform data category changes.