Research Data Retention and Deletion Policy.
1. Purpose and scope
This policy states how long Marker Learning keeps information collected from participants in its research studies, and how that information is deleted. It applies to all information collected from or about research participants, including children, in the Marker Learning Norming Study and in any related research data collection.
Marker Learning does not retain personal information collected from a child for longer than is reasonably necessary for the specific purpose for which it was collected. Marker Learning does not retain such information indefinitely.
2. Purposes for which information is retained
Information collected in the norming study is retained only to support the following purposes: (i) developing, validating, and maintaining assessment norms over time; (ii) conducting research, alone and with partner research institutions, and publishing the results; (iii) developing and improving assessment products and scoring methods; and (iv) training and validating automated scoring models.
Information is not retained for any other purpose. Information is not retained, used, or disclosed for advertising, marketing, or profiling, and is not sold.
3. Retention schedule
The following periods run from the stated trigger and are enforced by scheduled deletion jobs and by periodic manual review.
| Category | Retention period | Trigger |
|---|---|---|
| Contact and administrative information, including the participant identifier key file linking a study code to a named participant | 36 months, extended to 60 months where the participant has elected future contact | Last completed session |
| Audio recordings and video recordings | 36 months, or earlier upon satisfaction of the purposes in Section 2 | Session in which the recording was made |
| Images and scans of handwritten and drawn work | 36 months | Session in which the work was produced |
| Self-reported disability and diagnostic information, as provided by the participant or parent | 36 months | Last completed session |
| Coded research data: item responses, response process data, scores, model output, and coarsened background information | No fixed period. Retained for as long as needed for the purposes in Section 2 | Not applicable |
| Executed consent and assent forms | 7 years | Last completed session |
Why the coded research dataset has no fixed period. The coded research dataset does not contain names, contact details, or any other direct identifier, and indirect details are coarsened so that they cannot be used to work backward to an individual. Once the identifier key file described in the first row is destroyed, the coded dataset can no longer reasonably be linked to any individual and is no longer personal information. Retention of that dataset is therefore not limited by this policy. Destruction of the key file at the end of its retention period is the control that makes this true, and it is not discretionary.
4. How deletion is performed
- Records scheduled for deletion are identified by automated query against the retention triggers in Section 3.
- Electronic records are deleted from production systems and from all indexes and caches. Cryptographic erasure is used where deletion in place is not technically available.
- Backup media are not restored to recover deleted records. Records persisting in backup media are overwritten in the ordinary backup rotation, which completes within 30 days.
- Paper records, including scanned handwritten and drawn work, are cross-cut shredded or destroyed by a bonded destruction vendor that issues a certificate of destruction.
- Deletion is logged. The log records the category, the record count, the date, and the individual who performed or verified the deletion. Deletion logs are retained for 7 years.
5. Participant and parent deletion requests
A participant, or the parent or legal guardian of a participant, may request deletion at any time by contacting hello@markerlearning.com. Marker Learning verifies the identity of the requester before acting, and responds within 45 days, subject to any extension permitted by applicable law.
On a verified deletion request, Marker Learning deletes the contact and administrative information, the corresponding entry in the identifier key file, any self-reported disability and diagnostic information, and all audio recordings, video recordings, and images of handwritten and drawn work associated with the participant. Marker Learning also directs any research partner holding those files to delete them and obtains written confirmation.
Following deletion, the participant’s responses remain in the coded research dataset in a form that can no longer be connected to the participant. Two limits are disclosed in the consent form and apply here as well. Research findings already published cannot be withdrawn, and the influence of data already used to train an automated scoring model cannot be technically removed from that model, although the data will not be used in any future training.
A parent may also review the personal information collected from their child, refuse to permit further collection or use, and direct deletion, without any condition on continued participation other than that participation may not be able to continue if the information is necessary to the study.
6. Service providers and research partners
Service providers are contractually required to delete information on the same schedule and to certify deletion. Research partners receive data under a data use agreement that requires return or destruction on completion of the approved research, and in no case later than the periods in Section 3 for any category listed there.
7. Review
This policy is reviewed at least annually, and following any material change to the study design, the categories of information collected, or applicable law. The owner identified above is responsible for the review and for confirming that scheduled deletion is in fact occurring.
8. Contact
Questions about this policy may be directed to Marker Learning at hello@markerlearning.com.