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PIPEDA Schedule 1 Compliant Retention

Data Retention & Destruction Policy

Last updated: October 2026 · Governing Authority: Canadian PIPEDA & Privacy Act

1. Principle of Limited Retention

Under Principle 5 of Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), personal information must only be retained as long as necessary to fulfill the purposes for which it was collected.

At GCMSFile.ca, personal data collected during Access to Information and Privacy (ATIP) intake is held strictly to facilitate statutory filing with Immigration, Refugees and Citizenship Canada (IRCC), the Canada Border Services Agency (CBSA), or the Canadian Security Intelligence Service (CSIS), and to ensure safe delivery of your government disclosure package.

2. Retention Timelines

Data CategoryRetention PeriodDestruction Protocol
IMM 5744 Signed Consent Forms90 days post-fulfillmentCryptographic deletion from Canadian S3 storage
Released Government GCMS / ATIP PDFs90 days from release dateAutomated purging with zero archival duplication
Identity Documents & PassportsPurged once IRCC acknowledges ATIP receiptIrreversible binary overwrite
Billing / Payment Receipts7 years (Canadian tax law requirement)Processed exclusively by Stripe; zero card data stored

3. Right to Immediate Erasure (Right to Be Forgotten)

Applicants have the statutory right to request immediate destruction of their file once their GCMS notes have been downloaded. To exercise your right to erasure, simply email privacy@gcmsfile.ca or support@gcmsfile.ca with your tracking number.

Upon receiving your request, our Data Protection Officer will execute immediate cryptographic erasure of all associated files and logs within 48 business hours.

4. Storage Architecture & Encryption

  • All applicant files are hosted strictly within Canadian borders (AWS ca-central-1 region).
  • Data is encrypted at rest using AES-256 standard and in transit using 256-bit TLS 1.3 encryption.
  • Under no circumstances is applicant data sold, rented, monetized, or shared with third-party advertisers.
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