MICROCHIP CONNECT
DATA RETENTION & DELETION

1. ABOUT THIS POLICY

This Data Retention & Deletion Policy explains how Why Go Digital Ltd, when operating Microchip Connect, manages the retention, deletion, anonymisation and preservation of information processed through the Microchip Connect platform.

Microchip Connect processes different categories of information for different operational, contractual, security, registration, accounting and legal purposes.

Not all information is retained for the same period.

Why Go Digital Ltd aims to retain information only for as long as it is reasonably required for the purpose for which it is processed or where continued retention is required or permitted for another lawful purpose.

2. OUR RETENTION PRINCIPLES

Microchip Connect follows these principles:

• Personal data should not be retained for longer than reasonably necessary for the relevant lawful purpose.
• Microchip provenance and traceability information may be retained where there remains a legitimate operational, contractual, regulatory or legal reason for doing so.
• Historical records should not be silently overwritten where doing so would destroy important traceability or audit information.
• Access to retained information should be restricted to authorised users and systems.
• Information should be protected throughout its retention period.
• Information that is no longer required should, as appropriate, be deleted, anonymised, aggregated or otherwise removed from active use.
• Different categories of information may have different retention periods.
• Microchip provenance data and keeper personal data must be treated as different categories.

3. IMPORTANT DISTINCTION — MICROCHIP PROVENANCE VS PERSONAL DATA

Microchip Connect must distinguish between microchip provenance / traceability data and keeper / customer personal data.

Example provenance record:

This provenance information may continue to be required even where unnecessary keeper personal information is deleted or anonymised.

Do not assume that preserving microchip traceability requires retaining the keeper’s:

• name;
• full address;
• telephone number;
• or email address

for the same period.

4. DATA CATEGORIES

5. RETENTION SCHEDULE

Microchip Connect retention schedule

These periods are operational retention rules and may be amended where a different legal, contractual, regulatory or litigation requirement applies.

6. MICROCHIP PROVENANCE HISTORY

Microchip Connect must preserve an appropriate provenance history.

MICROCHIP
        ↓
SUPPLIED BY COMPANY A
        ↓
ALLOCATED TO ALL001
        ↓
RETURNED
        ↓
REALLOCATED TO BRI001
        ↓
IMPLANTED
        ↓
REGISTERED

Do not silently overwrite ALL001 with BRI001 and destroy the previous allocation.

Instead retain:

• Previous Allocation
• New Allocation
• Date
• Reason
• Source
• Status

This creates an auditable history. Where long-term traceability is required, retain the minimum necessary provenance record.

7. DELETION OF PERSONAL DATA

When personal data is no longer required, Why Go Digital Ltd should, as appropriate:

• delete;
• anonymise;
• remove identifying information;
• aggregate;
• or retain only the minimum record required.

The fact that Microchip Connect retains a microchip number or Registration Transaction does not automatically mean it must retain the keeper’s full personal information.

8. RIGHT TO ERASURE

Individuals may have a right to request erasure of personal data in certain circumstances. The right to erasure is not absolute.

Why Go Digital Ltd may retain information where continued retention is required or permitted for purposes including:

• legal obligations;
• contractual obligations;
• fraud prevention;
• security;
• accounting;
• regulatory requirements;
• establishment, exercise or defence of legal claims;
• and other lawful reasons.

Where another organisation is the relevant Data Controller, Why Go Digital Ltd may need to refer the request to or act on instructions from that organisation.

9. ACCOUNT CLOSURE

Closing or terminating an account does not automatically mean immediate deletion of every record.

On account closure:

• user access may be removed;
• API credentials may be revoked;
• integrations may be disabled;
• active functionality may cease.

However, Why Go Digital Ltd may retain records required for:

• accounting;
• contracts;
• audit;
• security;
• microchip provenance;
• registration reconciliation;
• disputes;
• legal claims;
• and regulatory obligations.

This applies to Microchip Company accounts; Veterinary Practice accounts; user accounts; and technical integrations.

10. DESTINATION MICROCHIP DATABASE DATA

Participating Microchip Databases operate independently unless expressly stated otherwise.

Once registration data has been transmitted to the destination Microchip Database, that database may retain the final registration record in accordance with its own:

• Privacy Policy;
• Data Retention Policy;
• Terms & Conditions;
• legal responsibilities;
• and regulatory requirements.

Deleting information from Microchip Connect does NOT automatically delete the independent database’s record. Customers may need to contact the destination database separately.

11. VETERINARY PRACTICE DATA

Veterinary Practices may retain information independently within their own Practice Management Systems or clinical records.

Microchip Connect does not control the deletion of independent Veterinary Practice records. Deleting information from Microchip Connect does not automatically delete information from the Veterinary Practice’s systems.

12. MICROCHIP SUPPLIER DATA

Microchip Suppliers may retain independent records including:

• stock;
• orders;
• dispatches;
• customer records;
• invoices;
• batch information;
• and allocation records.

Deleting information from Microchip Connect does not automatically delete records held by the supplier.

13. FAILED AND INCOMPLETE REGISTRATIONS

Failed registrations must not disappear immediately.

Microchip Connect may retain sufficient information to:

• identify the transaction;
• investigate the problem;
• retry eligible failures;
• prevent duplicate registrations;
• resolve exceptions;
• reconcile status;
• and provide support.

Statuses used include: PENDING, QUEUED, CUSTOMER ACTION REQUIRED, FAILED, REJECTED, UNRESOLVED, MANUAL REVIEW.

Once the issue is closed and the retention period expires, delete or anonymise unnecessary keeper personal data.

14. CUSTOMER ACCEPTANCE RECORDS

Where a destination database requires customer acceptance, Microchip Connect may retain:

• date/time acceptance requested;
• delivery status;
• acceptance status;
• acceptance date/time;
• refusal status;
• no-response status;
• and related transaction reference.

Retain only what is reasonably required to demonstrate the history and status of the registration.

Customer acceptance of registration must remain separate from marketing consent.

15. BACKUPS

Microchip Connect may maintain backups for disaster recovery; resilience; security; and system restoration.

Where data is deleted from the live system, it may remain temporarily in backup copies.

The current initial design assumption is a 90-day rolling backup retention period, unless the final production infrastructure uses another formally approved schedule.

Backups containing deleted information should naturally expire through the backup rotation process.

Deleted information should not normally be restored into active use unless required as part of a legitimate disaster-recovery operation.

Where backups are restored, applicable deletions and retention controls should be reapplied where reasonably practicable.

16. DATA SECURITY DURING RETENTION

Retained information must remain protected throughout its retention period.

Appropriate controls may include:

• authentication;
• role-based permissions;
• tenant isolation;
• access controls;
• audit logging;
• credential management;
• secure backups;
• monitoring;
• and other technical and organisational controls.

Access should be limited to authorised users and systems with a legitimate reason to access the information.

17. PERSONAL DATA BREACHES

Why Go Digital Ltd will investigate suspected personal-data breaches affecting Microchip Connect.

Where a breach occurs, Why Go Digital Ltd will assess:

• the nature of the information affected;
• the individuals affected;
• likely consequences;
• severity of risk;
• and required action.

Where applicable law requires it, Why Go Digital Ltd will notify the Information Commissioner’s Office; affected Data Controllers; and/or affected individuals within the applicable legal requirements.

Participating organisations must notify Why Go Digital Ltd promptly if they become aware of an incident affecting Microchip Connect information or integration credentials.

18. DATA CONTROLLER AND DATA PROCESSOR

Why Go Digital Ltd may have different roles depending upon the processing activity.

Why Go Digital Ltd may act as DATA CONTROLLER for:

• Microchip Connect company accounts;
• platform administration;
• security;
• billing;
• its own contractual records;
• fraud prevention;
• and its own business administration.

Why Go Digital Ltd may act as DATA PROCESSOR where it processes personal data on behalf of a Veterinary Practice; a Microchip Database; a Microchip Supplier; or another participating Data Controller.

Where Why Go Digital Ltd acts as a Data Processor, retention and deletion may also be governed by the relevant Data Processing Agreement; commercial agreement; and lawful instructions of the Data Controller.

19. UK DATA PROTECTION AND RECORD-KEEPING FRAMEWORK

Why Go Digital Ltd handles personal data in accordance with applicable UK law, including where relevant:

• UK General Data Protection Regulation (UK GDPR);
• Data Protection Act 2018;
• Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), where applicable;
• applicable taxation and accounting record requirements;
• applicable company record obligations;
• applicable contractual and litigation requirements;
• and guidance issued by the Information Commissioner’s Office.

No single one of these laws requires all Microchip Connect records to be retained for the same period.

20. STORAGE LIMITATION

Microchip Connect therefore applies retention periods according to:

• purpose;
• category of information;
• legal requirements;
• security requirements;
• contractual obligations;
• accounting obligations;
• traceability requirements;
• and whether the information remains necessary.

Personal data must not be kept indefinitely merely because it is technically possible to retain it.

21. INDIVIDUAL RIGHTS

Depending upon the circumstances, individuals may have rights including:

• right to be informed;
• right of access;
• right to rectification;
• right to erasure;
• right to restrict processing;
• right to data portability;
• right to object;
• and rights relating to certain automated decision-making.

Not all rights apply in every circumstance. Where another organisation is the Data Controller, Why Go Digital Ltd may refer or assist with the request.

22. DATA REQUESTS

Requests concerning personal information processed by Why Go Digital Ltd through Microchip Connect should be sent to admin@whygodigital.co.uk.

Why Go Digital Ltd may require reasonable identity verification before disclosing; changing; exporting; or deleting personal data.

The purpose is to prevent unauthorised disclosure or deletion.

23. RETENTION HOLDS

Where information would normally be deleted but is required because of:

• ongoing litigation;
• threatened legal proceedings;
• regulatory investigation;
• fraud investigation;
• security incident;
• contractual dispute;
• or another legal obligation,

Why Go Digital Ltd may place the relevant information under a retention hold.

During a retention hold, normal deletion may be suspended for the affected information. Once the hold is no longer required, the normal retention schedule should resume.

24. AUTOMATED DELETION

The platform architecture is being prepared so that retention periods can eventually be automatically enforced, supporting future fields such as:

• retention_category
• retention_start_date
• retention_until
• deletion_status
• anonymised_at
• deleted_at
• retention_hold
• retention_hold_reason

Automatic deletion will not be implemented without proper testing and approval. The system must never automatically delete records subject to a retention hold.

25. RETENTION SCHEDULE ADMINISTRATION

A future MC Admin function, DATA RETENTION, may eventually allow authorised administrators to:

• view retention categories;
• view retention periods;
• review records approaching deletion;
• view anonymisation activity;
• view deletion activity;
• apply authorised retention holds;
• release retention holds;
• and review retention exceptions.

26. POLICY REVIEW

Why Go Digital Ltd should periodically review the retention schedule. Review may be required because of:

• legal changes;
• ICO guidance;
• changes in Microchip Connect functionality;
• new database integrations;
• new supplier integrations;
• security requirements;
• operational changes;
• accounting requirements;
• or experience gained from actual platform use.

The effective date should be updated whenever a material change is made.

27. CONTACT

Microchip Connect is operated by:

Microchip Connect does not currently operate a public website.

28. COMPLAINTS

Anyone with concerns about how Why Go Digital Ltd retains, uses, deletes or anonymises their personal information should contact admin@whygodigital.co.uk.

Individuals may also have the right to complain to the Information Commissioner’s Office (ICO).