Information Technology SOP X: Guest Data Retention & Deletion (Booking System + Puttshack Perks) — US & UK
Document Information
Purpose
This SOP establishes standardized procedures for retaining, securing, and deleting guest personal data collected through Puttshack’s booking system and Puttshack Perks (loyalty program, including SMS/email marketing) across the United States and the United Kingdom. It aligns operational practices with Puttshack’s published privacy commitments and ensures consistent handling of data subject requests (especially deletion).
Scope
This SOP applies to all Puttshack personnel, processes, and systems that create, access, store, export, or process guest personal data in connection with:
Out of scope: EU-only requirements and EU-specific processes. UK coverage remains in scope.
Policy Statement (Retention & Deletion Rule)
Procedures
A. Retention (Default)
B. Guest Deletion Requests (Bookings + Perks)
C. Deletion Exceptions
Deletion may be denied or limited where retaining information is necessary to:
Appendix A: Retention Schedule (Infrastructure & Supporting Data)
Infrastructure data follows the schedule below to ensure system performance and security best practices.
Data Category | Retention Period | Rationale / Notes |
Primary Guest Profile (Booking/Perks) | Booking: 5 years Perks: 5 years after guestindicates they no longer want to participate in the program | Reasonable, justified retention period based on business purpose. |
AWS Live Backups (Point-in-Time Recovery) | 35 Days (Rolling) | AWS RDS/DynamoDB backups are captured live. Data is overwritten/expired on a rolling basis. |
System & Application Logs (CloudWatch/S3) | 1 Year | Retained for security auditing, troubleshooting, and fraud investigation. |
Transactional Email/SMS Metadata | 2 Years | Records of message delivery (not necessarily content) for operational tracking. |
Customer Support Tickets (Resolved) | 7 Years | Retained for historical context and legal defense (e.g., incident records). |
Payment Metadata (Non-PCI) | 7 Years | Transaction IDs and amounts (no card numbers) for tax and accounting audits. |
Temporary Data Exports / Reports | 90 Days | Staff-generated exports must be deleted once the specific business task is complete. |
Video | (complete) | (complete) |
Note on AWS Live Backups
Puttshack utilizes AWS-native backup features (such as RDS Automated Backups or DynamoDB Point-in-Time Recovery) that capture changes live as they occur. When a guest is deleted from the production database, that deletion is reflected in the live state. Because backups are point-in-time snapshots, a deleted guest may still exist in historical backup files for the duration of the rolling retention period (e.g., 35 days). In the event of a system restore, IT must ensure that any guest deletion requests processed after the backup timestamp are re-applied to the restored production environment.
Compliance
Revision History
Timelines Summary
Step | Actor | Timeframe |
Intake & Ticket Creation | Guest Services | Within 2 business days |
Identity Verification | Guest Services + Privacy/Legal | Within 5 business days |
Systems Identification | IT | Within 5 business days of verification |
Deletion Execution | IT | Within 10 business days |
Guest Confirmation | Guest Services | Within 3 business days after completion |