Retention periods for removed customers
Introduction
From 25 May 2018, new rules for the protection of privacy (AVG / GDPR) will apply. This also affects how long customer data may be kept. The period for which the data is kept is called the retention period. Some data may (or must) be kept longer than others; for example, financial data must be kept for seven years for tax reasons. The information that OCLC retains and for how long is described below.
Membership retention periods
The image below shows an example of a customer's membership and the retention periods for this customer's data.
The green bar represents the customer's membership period. The customer registers on 1 January 2015 and receives a membership fee invoice. The invoice is paid on January 1, 2016 etc. The customer has been a member for a number of years, and in Q4 of 2022 they cancel their membership. After that the customer is no longer a member.
Membership fee
The agreement - and also the legal obligation - is that OCLC keeps the financial records of this customer for seven years. The image shows that from January 1, 2015, the financial rules relating to the membership fee will be saved up to and including Q4 2021. After that, these rules will be removed from the system. The data from 2016 will be kept up to and including Q4 2022, etc. The data from the last year of membership (2022) will be kept in the system up to and including Q4 2028. This also applies to the actor.
Loans
In the case of loan transactions, it can be seen that the customer borrowed something in 2015: this transaction has been in the system for two years according to the agreed library term. This information is kept for two years, after which the loan transaction is anonymized and disconnected from the borrower (so the information is not thrown away).
Fines
The same applies to fines as to the membership fee: this information must be kept for seven years. The customer in the example caused a penalty in the last year of their membership (Q3 of 2022). This information will then remain in the system up to and including Q2 2029.
Title previously borrowed
This is subject to a retention period of two years after termination of membership. After these two years, the data is gone.
Conclusion
The customer cancels their membership in Q4 2022, but in this case, the actor has completely disappeared in Q3 2029.
Overview
The table below provides an overview of when certain customer information is deleted, depending on whether the customer is active or inactive.
When is information deleted:
| Information | Customer Active | Customer Inactive |
|---|---|---|
| Name and address + phone + e-mail | 7 years after cancellation | |
| Membership (roles) | Information older than 2 years | |
| Title previously borrowed | 2 years after cancellation | |
| Asset Profiles | 2 years after cancellation | |
| Loan history | Information older than 2 years | |
| Instance history | Information older than 2 years | |
| Holds | Information older than 2 years | |
| Marketing/Newsletter | Information older than 2 years | |
| KSM | Information older than 2 years | |
| Customer notifications | Information older than 2 years | |
| To inform | Information older than 2 years | |
| Tickets | Information older than 2 years | |
| Customer account changes | Information older than 7 years | |
| Blocks | 2 years after cancelation | |
| Documents (permission) | 7 years after cancelation | |
| Pass/Username | 2 years after cancelation | |
| Relationships | 2 years after cancelation | |
| Collection records | Information older than 2 years | 2 years after cancelation |
| Collections agency | Information older than 2 years | 2 years after cancelation |
| Financial Transactions | Information older than 7 years | 7 years after cancelation |
If a customer is removed via the client, it will get a different actor_id, so that it can no longer be traced back to the real actor (actor is anonymized). When anonymizing loans, only the actor_id is anonymized. Information such as membership number, district, and zip code, etc. will remain.
It is possible to cancel and reactivate a membership, but only within two years. After two years, the actor is gone, so the customer must be registered again. The name and address details are still present (these are only deleted after seven years of inactivity), but the password and username are gone after two years.
Deletion Conditions
Sometimes data remains transparent, even though the information should have been removed or anonymized according to the table above. There are a number of conditions for removing actors.
The actor must not:
- records have more in fin_posten
- have more records in fin_posten_archive that are younger than the set number of months (financial_inactive)
- borrowed more copies
- role of the EDUB type whose deregistration date is younger than 3 months
- role of the type ABON or EDUV where the end date is younger than 24 months
- role of type VEST or EXTR
- record more in table wise_rol
- record more in actor_blockade of type ALG or DEU
- record more in the role_supplier table
- record more in the role_levr_external table
- have more record in actor_auth_agent where username is used as port id for SIP machines
- record more in role_location
- have record more in role_external
- have record more in role_vest_extern
- have record more in role_personnel
- System option NOAFVLN does not affect the retention cleanup routine.
- Actors with an empty end_date in role of type 'SUBSCRIBE' are never cleaned up
- Actors with a status < 8 of type 'ABON' in table 'role' are never cleaned up
- Actors with a role 'EXTR', 'XTRN' or 'VEST' are never cleaned up
- Actors with a role 'ABON' with subtype (value) 'SPEC' or 'ADMI' are never cleaned up
If any of the above still apply, the actor will not be removed.
Set in the manager
In SystemWise > System Settings, four fields have been added for a term for retention periods (GDPR). These values cannot be changed; they are only transparent so that the customer can see the retention. The default value = 0, that means it is not enabled in the system. At the customer's request, OCLC will maintain these values for the customer. OCLC must maintain these values because if the fields in the manager are filled in incorrectly, there is a risk of accidentally removing actors.
These values are in the wise_system table.
When these settings are entered by OCLC, this process will not be performed all at once, but over a period of time. Depending on the size of the system, this will take a few days or weeks. At the end of the process, the inactive actors are removed from the system.
Wise cleanup
Actors are removed via the job wise cleanup. This job runs every ten minutes and can be tracked via the Dashboard .
To see how many actors and associated data have been deleted in a given time period, use the 'Deleted customer records per day' report. This report can be requested via Manager > SystemWise > Reports > Reports (set up by function) > Deleted customer records per day.