Data Retention Policy

Purpose

This policy sets how long Lexoral keeps each category of personal information and proceeding materials, and how they are securely deleted when that period ends.

Lexoral keeps personal information only as long as needed for the purposes for which it was collected, to meet its legal obligations and to run its legitimate business. We keep nothing “just in case” and nothing indefinitely.

Scope

This policy covers all personal information and proceeding materials held by Lexoral, including:

• Audio and video recordings submitted for transcription
• Completed transcripts, working drafts and attestation documents
• Exhibits, glossaries and reference documents supplied with proceedings
• Client contact details and engagement history
• Billing and payment records
• Written correspondence (email, messages) about a file
• Technical and access logs

Retention schedule

The table below sets the default retention periods. Each runs from the event shown.

These are default periods. A client may ask at any time for shorter retention or for immediate deletion of specific categories (see L. 08). Longer retention may apply where the law or a legal hold requires it (see L. 09).

Audio recordings

Recordings submitted for transcription are the most sensitive materials Lexoral handles: they hold legal proceedings word for word and may contain privileged communications, deponents’ personal information and confidential business information.

We delete every submitted recording within 30 days of delivering the transcript. A client who wants earlier deletion can ask when sending the file or at any time during the engagement.

Deletion is done by secure erasure that makes the data unrecoverable. On request, Lexoral provides written confirmation of deletion.

Transcripts and attestation documents

Completed transcripts and attestation documents (signed accuracy declarations, delivery confirmations) are kept for 2 years from delivery, which allows us:

• To supply a replacement copy at the client’s request
• To verify accuracy or formatting if either is challenged
• To support a proceeding in which the transcript is tendered as evidence

A client who does not need this retention may ask for deletion at any time after delivery; a client who needs longer retention for ongoing litigation may ask for it in writing.

Client records

Client contact details, engagement history and billing records are kept according to the schedule above. Billing records are subject to a mandatory 7-year retention under applicable Canadian tax law; that period cannot be shortened on request.

File correspondence (emails, WhatsApp messages and other written exchanges about a proceeding) is kept for 2 years after delivery and then permanently deleted, unless a legal hold applies.

Deletion procedures

When each retention period ends, Lexoral permanently and securely deletes the data concerned. Our procedures include:

• Secure overwrite erasure of files stored on systems Lexoral controls
• Verified deletion requests to any provider holding a copy
• An internal record of each deletion, with date and method
• Written confirmation to the client on request

Every quarter, Lexoral reviews all stored materials against this schedule and deletes whatever has passed its retention period.

Deletion at the client’s request

A client may ask at any time for permanent deletion of all or part of the materials relating to their file, on these terms:

• The request is made in writing to secure@lexoral.org, identifying the file and the materials concerned
• Lexoral processes the request within 7 business days
• Written confirmation of deletion is provided once the request is processed
• Billing records under mandatory tax retention cannot be deleted before the 7 years have passed
• If a legal hold is in place, deletion is deferred until the hold is lifted

Legal hold

When Lexoral learns, from its client or its own legal advisers, that materials may be relevant to pending or anticipated litigation, a regulatory investigation or a court order, a hold may be placed on those materials, suspending the normal deletion schedule.

Materials under a hold are kept until the instructing party or Lexoral’s legal advisers formally lift it. Lexoral tells the client about any hold on their materials and the reason for it, to the extent the law permits.

Review and accountability

This policy is reviewed every year and updated as needed. Brian Fino, the person in charge of the protection of personal information at Lexoral (brian.fno@proton.me), is responsible for implementing and enforcing it.

Anyone concerned about our retention practices can write to us directly or complain to Quebec’s Commission d’accès à l’information or to the Office of the Privacy Commissioner of Canada.

Contact

For deletion requests, questions about this policy or any concern:

• Person in charge (Quebec Law 25) — Brian Fino, co-founder: brian.fno@proton.me
• Files and deletion requests — secure@lexoral.org
• Telephone — +1 (514) 712-7516
• Mailing address — 24191-300 Eagleson Rd, Kanata, Ontario K2M 2C3, Canada