As the data processor, Aptem will act on the instructions of the data controller (Yourselves), and data is deleted on request only. This ensures manual oversight, so no data is accidentally deleted, or deleted too early, simply due to automated processing.

When Aptem initiates data removal, the data is initially only hidden from the system view and is then fully removed 30 days later via an automated process. This allows for a short period of data recoverability, should a request have been made in error. At the point when a learner is fully removed, all documents associated with the learner will also be removed.