Policy on the retention, destruction and anonymization of personal information
Updated May 18, 2026
This policy describes our principles regarding retention periods, secure destruction and anonymization of personal information. It supplements the Privacy Policy where we refer to it for retention purposes.
Compliant with Quebec's Law 25
1. Objective
This policy establishes the rules applicable to the retention, use, archiving, anonymization and destruction of personal information processed as part of the Background Buddy service (“the platform”).
This policy aims in particular to:
- contribute to compliance with the Act respecting the protection of personal information in the private sector (Quebec — Law 25) where that law applies to us;
- align with the principles of the GDPR where that framework also applies to us;
- reduce the risks of unauthorized access to personal information;
- limit excessive retention of data as far as reasonably possible in a cloud hosting context;
- promote the traceability of relevant decisions when data is deleted or anonymized.
2. General principles
2.1 Retention limitation
Personal information is kept only for a period related to legitimate needs, in particular:
- the purposes for which it was collected;
- the contractual obligations binding us to the customers and users concerned;
- the applicable tax, accounting, union or legal obligations;
- prevention or defense in disputes relating to the service;
- the security of the service and of users.
2.2 Destruction or anonymization
Where the expired purposes allow it and subject to legal exceptions:
- personal information is securely deleted where appropriate; or
- it may be subject to irreversible anonymization where continued use in aggregated or statistical form is legitimate and compatible with privacy.
2.3 Minimization
As far as possible given the service offered, we aim to:
- limit the amount of data collected to operational and legal needs;
- restrict access according to roles and context (e.g. production);
- avoid prolonged duplication where reasonable alternatives exist.
3. Data categories and retention periods
The following periods represent our internal framework and the usual practices envisaged. They may be adjusted where the law, a contract or a dispute requires different or longer periods.
| Data category | Examples | Indicative retention period | Justification (excerpt) | End of retention (intended) |
|---|---|---|---|---|
| Active user accounts | Name, email, phone, application roles | As long as the account is active | Provision of the service | Deletion or anonymization |
| Inactive accounts | Account data with no significant activity | Up to 24 months after inactivity is noted | Operational management, possible recovery | Automated processing then deleted or anonymized |
| Production data | Assignments, call times, availability | Up to 7 years | Possible disputes, operational evidence | Archiving then anonymization where relevant |
| Signed electronic contracts | Background-actor contracts (e.g. UDA/ACTRA), receipts | At least 7 years | Accounting and tax retention and contractual evidence | Secure archiving then deletion outside legal deadlines |
| Tax data | SIN, tax residence, tax references | At least 7 years | Tax obligations (Canada or other relevant regime) | Secure deletion after the deadline |
| Identity documents | Supporting documents, work permits | End of validity of the document or up to 24 months without activity | Administrative verifications and compliance | Automated deletion processing after the deadline |
| Minors' data | Authorizations, emergency contacts | Up to 3 years after the age of majority or the end of the contract (as the case may be) | Protection of minors, civil liability | Enhanced deletion |
| Health data or physical restrictions | Allergies, limitations, specific needs mentioned | Duration of the project + 12 months (indicative) | On-set safety | Priority to deletions as soon as legitimately expired |
| Photos and measurements | Sizes, outfits, casting photos | 24 months after last activity (indicative) | Casting and creative/production follow-up | Deletion or anonymization |
| Communication history | Email sending logs, confirmations | Up to 24 months (indicative) | Traceability and proof of communication | Anonymization of metadata where possible |
| Technical and security logs | IP addresses, access logs, authentication attempts | Up to 12 months (indicative) | Cybersecurity, incident analysis | Automatic purge according to the configured window |
| System backups | Encrypted copies of databases or files | Indicative rolling window (e.g. 90 days) | Business continuity | Automatic overwriting outside the window retained by the host |
| Aggregated analytics data | Genuinely anonymized usage statistics | No limit where anonymization is irreversible | Product improvement | Not applicable (non-identifiable data) |
4. Automatic deletion and automated processing
Where automated mechanisms are in place in the environment operated for the service:
- flag or expire certain data at a fixed or relative date;
- delete or archive outside active databases after the deadline;
- anonymize histories for non-identifying purposes;
- purge temporary files and old logs where configured to do so;
- respect the backup lifecycle managed by the underlying hosting.
4.1 Regular processes
Scheduled tasks (“cron jobs”, queues or maintenance scripts) may be run to identify records that have reached their deadline, delete or anonymize them, and notify internally where the law requires monitoring.
4.2 Deletion methods — principles
Depending on the type of data and the technologies used:
- deletion or logical deactivation followed by physical erasure outside the backups remaining within the host's deadlines;
- overwriting or cryptographic deletion where keys allowing reading can be safely removed.
5. Anonymization
Once irreversibly anonymized, data generally ceases to be personal information where no reasonable re-identification is possible. We strive to apply recognized techniques given the context when we keep long-term statistics.
Pseudonymization is not, on its own, sufficient to constitute anonymization if re-association remains easy with other data sets under our control.
6. Handling user requests
You can exercise your applicable rights as described in our Privacy Policy (access, rectification, deletion within legal limits, withdrawal of consent where processing is based on it, etc.). Some data will have to be kept despite a deletion request where a legal obligation or an equivalent legitimate interest requires us to do so until the end of the applicable period.
7. Security during retention
When personal information is kept, we rely in particular on:
- encryption in transit (e.g. HTTPS);
- the measures offered by our hosts for storage at rest;
- role-based access controls and functional scopes within the application;
- access logging for sensitive uses where implemented;
- the strong authentication offered by our identity provider where configured as such.
8. Responsibilities
The person responsible for the protection of personal information (name and contact details detailed in the Privacy Policy where required) oversees the application of this policy, the updating of the periods where necessary, and may approve documented exceptions where the law permits and where the residual risk has been assessed.
9. Review of this policy
We aim for at least an annual review of this page, as well as an update in the event of:
- major regulatory changes affecting us;
- substantial transformations of our data processing relating to the periods described above.
10. Legal and contractual references (non-exhaustive)
This policy draws in particular, depending on the cases applicable to us, on:
- the Act respecting the protection of personal information in the private sector(Quebec — Law 25);
- Quebec civil law where relevant;
- tax obligations in Canada where we or our customers process data in this way;
- the accounting retention practices generally used in the sector;
- the General Data Protection Regulation (EU) where processing is subject to it indirectly or directly;
- the contractual or union requirements related to audiovisual productions where the data and contracts require it.
Contact us
For any question related to retention periods or your rights, you can write to: