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Data and Security

Data and Records Retention and Destruction Policy

Automated deletion and clean-up periods (accounts, audit logs, notifications, backups); "Records Retention" is merged into this text.

Version
1.0
Effective
7 November 2026
Owner
Board of Directors, International Social Benefit Association (data controller)
Review
At least once a year and whenever a retention period changes
Category
Data and Security
Last updated
7 November 2026

نسخه‌های الزام‌آور ترکی و انگلیسی هستند؛ اگر با هم تفاوت داشته باشند، متن ترکی ملاک است. متن سیاست‌ها به زبان انگلیسی نمایش داده می‌شود.

زبان متن

1. Purpose and place of this document

To explain how long we keep personal data and organisational records and how we delete or anonymise them at the end of that period. This policy combines the requested "Data Retention and Destruction" and "Records Retention" topics in one text so that retention periods are kept in one place. Maximum retention periods by category are in the table of the existing Data Retention and Destruction Policy (contracts: veri-saklama-ve-imha-politikasi); this text does not change that table but adds the periods that are applied automatically.

2. Scope

The Firestore database, authentication records, file storage, backups, notification and audit logs; the Association's books, documents and correspondence records.

3. Principles

  1. Data is not kept longer than needed for its purpose.
  2. Records that must be kept by law are not deleted; they are anonymised by cutting the link to the person.
  3. Destruction is recorded, but the destruction record does not carry the identity of the deleted person.
  4. Automated processes come before manual work.

4. Roles and responsibilities

  • Data controller (the Association): approves retention periods.
  • Technical lead: monitors that the automated deletion jobs run.
  • Super-admins: monitor deletion requests and destruction records.

5. How it works at hangel today

RecordWhat happensHow
User account (when deletion is requested)Deleted after a 30-business-day waiting periodAn automated job runs every day at 04:00 (Istanbul): the sign-in account, the user record and all its sub-records, the public profile, notifications, personal project drafts and the CV file are deleted
Acceptance and consent recordsNot deleted; anonymisedThe field identifying the person is replaced with an irreversible hash; the records cannot be changed from the app
Donation recordsNot deleted; anonymisedKept as financial records; the link to the person is cut
Audit logs2 yearsAutomated clean-up running every day at 04:30
In-app notifications12 monthsSame automated clean-up
Push notification tokens12 months if unusedSame automated clean-up
Disaster radio lock-screen tokenImmediately on leaving the channel, otherwise after 30 days at the latestAutomated clean-up
Database backups98 daysDaily automatic backup; deleted by the cloud provider when the period ends
Destruction recordsKeptEvery deletion and clean-up is recorded without the real user ID
  • Association records: The Association's books, income and expenditure documents and decision records are kept for the periods required by the Law on Associations (No. 5253), the Regulation on Associations and tax legislation.
  • Correspondence records: Correspondence with organisations is kept in a single file per organisation.

6. Not yet in place and our goals

  • Some periods in the existing Data Retention and Destruction Policy table differ from the automated practice (for example, the table says "duration of membership + 10 years" for account data, while in practice account data is deleted 30 business days after a deletion request; it says 90 days in backups for health data, while database backups are kept for 98 days). Our goal is a single, up-to-date table after legal review.
  • Files in file storage (photos, documents) are not deleted automatically on a time basis. On account deletion, the CV file and personal files uploaded to Projeni Yaz are deleted; other uploaded files such as profile photos and post images are not yet deleted.
  • On account deletion, the person's records in other collections, such as posts, event attendance records and volunteering applications, are not yet deleted or anonymised automatically. Our goal is to bring these records into the scope of deletion or anonymisation.
  • It is not possible to extract a single person's data from backups; data in backups is deleted automatically when the period ends.
  • No separate automated period is defined for some collections (for example event attendance records).

7. How to raise a concern

Deletion requests and retention questions: kvkk@hangel.org or Settings → Privacy in the app.

8. Review

At least once a year and whenever a retention period changes.

9. Related documents

Existing "Data Retention and Destruction Policy" · Personal Data Protection Policy · Information Security Policy · Crisis and Business Continuity Policy

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