Data retention policy
Studio Grace Limited · 16 October 2026 · Updated 3 November 2026
1. Purpose and scope
Studio Grace keeps client personal data only for as long as it needs it, then deletes or anonymises it on a fixed schedule. This policy sets that schedule and explains why each period was chosen.
It covers personal data about clients, prospective clients, newsletter subscribers and website visitors, held in any format: the booking system, email, payment platform, spreadsheets, paper forms and Ring doorbell recordings. Staff and instructor records are covered by a separate HR retention schedule.
Studio Grace Limited (company number 17441634) is the data controller.
2. Legal basis and principles
Every period below is tied to either a legal requirement or the time limit for a likely claim. The rules that set them:
- UK GDPR storage limitation (Article 5(1)(e)): data must not be kept longer than necessary, and the ICO expects a policy with standard retention periods that still allows early deletion.
- HMRC / Companies Act: a limited company must keep accounting records for 6 years from the end of the financial year they relate to.
- Limitation Act 1980: personal injury claims have 3 years and contract claims 6 years; for a client under 18, the 3 years only start at their 18th birthday.
Health information (injuries, conditions, pregnancy) is special category data. It is collected with explicit consent, seen only by staff who teach or manage the client, and kept with the client's Punchpass record for 6 years after their last activity.
3. Retention schedule
Client records in Punchpass are kept for 6 years after a client's last activity, because the same record holds the signed waiver and payment history that must be kept that long. "Last activity" means the client's last attended class, booking or purchase, whichever is latest.
| Data category | What it includes | Retention period | Why |
|---|---|---|---|
| Client account | Name, email, phone, address, date of birth, emergency contact | While active, then 6 years after last activity | Same Punchpass record holds the waiver and payment history (6-year contract and HMRC periods) |
| Booking and attendance history | Classes booked, attended, late-cancelled, no-shows | While active, then 6 years after last activity | Evidence of attendance if a claim or dispute arises |
| Health questionnaire (PAR-Q) and updates | Injuries, medical conditions, pregnancy, surgery, medication | While active, then 6 years after last activity | Shows the studio knew of and adapted for a condition |
| Accident and incident reports | What happened, who was involved, witnesses, first aid given | 3 years from the incident (under-18s: until their 21st birthday); if a claim is made, until it is closed | Injury-claim window |
| Signed waiver and terms acceptance | Date and version of terms and waiver agreed | 6 years after membership ends | Contract-claim window |
| Financial records | Invoices, receipts, refunds, membership and class-pack sales, gift vouchers | 6 years from the end of the financial year | HMRC record-keeping |
| Payment card details | Card number, expiry | Not held by Studio Grace; stored by the payment provider | Payment provider's own retention applies |
| Complaints and correspondence | Emails, messages, call notes | 2 years after the matter is closed | Enough to handle repeat or escalated issues |
| Enquiries from non-clients | Contact-form and DM enquiries, free-trial sign-ups that never booked | 12 months from last contact | No ongoing relationship |
| Marketing list | Name, email, mobile number, consent date and source, preferences, including guest list sign-ups from our website | Until unsubscribe, or 2 years with no opens or bookings | Consent goes stale without engagement |
| Unsubscribe (suppression) list | Email address only | Indefinitely | Needed to keep honouring the opt-out |
| Photos and video of clients | Marketing images with consent | Until consent is withdrawn; removed from live channels within 30 days | Consent-based |
| Ring doorbell footage | Video recordings from the Ring video doorbell at the studio | 30 days (set in the Ring app), then deleted automatically; footage of an incident downloaded and kept until it is resolved | Security only |
| Website analytics and cookies | IP address, device, pages visited | Punchpass analytics follow the client account (6 years after last activity); website cookies per cookie settings | Website improvement |
Where data is held under more than one row, the longest applicable period wins for that item only; the rest of the record follows its own row.
4. Deletion and anonymisation
A quarterly data cleanup deletes everything that has passed its period. The steps:
- Run a report in the booking system of clients with no activity in the last 6 years.
- Delete or anonymise those accounts, including attached health forms. Keep anonymised totals (class counts, revenue) for reporting.
- Remove leads older than 12 months and lapsed marketing subscribers, including guest list sign-ups held in Formspree and email; add unsubscribed emails to the suppression list.
- Shred paper forms past their period with a cross-cut shredder or a certified shredding service.
- Log the date, what was removed and who did it.
Deletion is paused for any record linked to an open complaint, claim, insurance matter or HMRC enquiry until it is closed. Backups held by suppliers roll off on their own cycle and are not restored except to recover from data loss.
5. Suppliers that hold client data
Studio Grace's suppliers store data on its behalf and must delete it when Studio Grace does or when the contract ends. Each has a data processing agreement in place.
| Supplier | Role | Data held |
|---|---|---|
| Punchpass | Bookings, memberships, client accounts, health forms, waivers, payments, analytics, and bookings from aggregators (e.g. ClassPass) | Account, attendance, PAR-Q, signed waivers, payment and transaction history, usage analytics |
| Stripe (connected through Punchpass) | Card payments and direct debits | Payment card details, transactions |
| Mailchimp | Newsletters and offers | Marketing list, suppression list |
| Netlify | Website hosting | Technical data such as IP addresses in website logs |
| Formspree | Guest list sign-up form | Guest list sign-ups (name, email, mobile number, source, consent) |
| GoDaddy (Microsoft 365) | Domain name and business email | Emails, including guest list sign-up notifications and enquiries |
| Ring | Video doorbell and cloud video storage | Video recordings of people at the studio |
When a client books through an aggregator, that platform is also a controller of the data and its own policy applies to what it holds.
6. Client rights, requests and review
Clients can ask Studio Grace to see, correct or delete their data at any time, and Studio Grace will respond within one month. If a client asks for deletion, everything is removed except what must be kept by law (financial records for HMRC, and any record linked to an open incident or claim); the client is told what is kept and why.
Clients can unsubscribe from marketing from any email or by asking at reception, without affecting booking confirmations or account messages.
This policy is owned by Studio Grace and reviewed every 12 months, next by 16 October 2027, or sooner if the booking system or the law changes. Complaints can also go to the Information Commissioner's Office.
- hello@studiogracewellness.co.uk
- Post
- Studio Grace Limited, 23 Main Road, Radcliffe on Trent, Nottingham NG12 2BE
See also our customer privacy notice.