Data retention policy
Data Retention
Arrows shall retain data as long as the company has a need for its use, or to meet regulatory or
contractual requirements. Once data is no longer needed, it shall be securely disposed of or
archived. Data owners, in consultation with legal counsel, may determine retention periods for
their data.
Personally identifiable information (PII) shall be deleted or de-identified as soon as it no longer
has a business use.
Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.
Data archiving and removal policy
Data & Device Disposal
Data classified as restricted or confidential shall be securely deleted when no longer needed.
Arrows shall assess the data and disposal practices of third-party vendors in accordance with
the Third-Party Management Policy. Only third-parties who meet Arrows requirements for
secure data disposal shall be used for storage and processing of restricted or confidential data.
Arrows shall ensure that all restricted and confidential data is securely deleted from company
devices prior to, or at the time of, disposal.
Confidential and Restricted hardcopy materials shall be shredded or otherwise disposed of
using a secure method.
Personally identifiable information (PII) shall be collected, used and retained only for as long as
the company has a legitimate business purpose. PII shall be securely deleted and disposed of
following contract termination in accordance with company policy, contractual commitments
and all relevant laws and regulations. PII shall also be deleted in response to a verified request
from a consumer or data subject, where the company does not have a legitimate business
interest or other legal obligation to retain the data.
Data storage policy
The company's datastores housing sensitive customer data are encrypted at rest
Confidential Data Handling
Confidential data is subject to the following protection and handling requirements:
Access for non-preapproved roles requires documented approval from the data owner
Access is restricted to specific employees, roles and/or departments
Confidential systems shall not allow unauthenticated or anonymous access
Confidential Customer Data shall not be used or stored in non-production
systems/environments
Confidential data shall be encrypted at rest and in transit over public networks in
accordance with the Cryptography Policy
Mobile device hard drives containing confidential data, including laptops, shall be
encrypted
Mobile devices storing or accessing confidential data shall be protected by a log-on
password (or equivalent, such as biometric) or passcode and shall be configured to lock
the screen after five (5) minutes of non-use
Backups shall be encrypted
Confidential data shall not be stored on personal phones or devices or removable media
including USB drives, CD's, or DVD's
Paper records shall be labeled "confidential" and securely stored and disposed of in a
secure, approved manner in accordance with data handling and destruction policies and
procedures
Hardcopy paper records shall only be created based on a business need and shall be
avoided whenever possible
Hard drives and mobile devices used to store confidential information must be securely
wiped prior to disposal or physically destroyed
Transfer of confidential data to people or entities outside the company shall only be done
in accordance with a legal contract or arrangement, and the explicit written permission of
management or the data owner
Restricted Data Handling
Restricted data is subject to the following protection and handling requirements:
Access is restricted to users with a need-to-know based on business requirements
Transfer of restricted data to people or entities outside the company or authorized users
shall require management approval and shall only be done in accordance with a legal
contract or arrangement, or the permission of the data owner
Paper records shall be securely stored and disposed of in a secure, approved manner in
accordance with data handling and destruction policies and procedures
Hard drives and mobile devices used to store restricted information must be securely
wiped prior to disposal or physically destroyed
Data center location(s)
United States
Data hosting details
Cloud hosted
Data hosting company
Heroku/AWS
App/service has sub-processors
yes
Guidelines for sub-processors
App/service uses large language models (LLM)
no