General Data Protection Regulations - Deletions

The content of this document is not legal advice.  

You should consult a legal advisor on your GDPR responsibilities.  

Changes have been made to Jupix to ensure that you (the controller of the data) can meet your obligations under the General Data Protection Regulations requirements.  

 

Deletions


Individual Deletions

There is a Delete Contact button on the Special Actions menu for Applicants,  Potential Vendors, Vendors, Potential Landlords, Landlords. and Contacts, the way this works is to delete all profiles for the contact.  

It is only available to users with permission to use this function.  

  1. When Delete Contact is clicked the deletion rules that have been turned on in your System Configuration will be checked  

  1. A Profile Summary will be displayed for the person that you are attempting to delete and you will be notified that “You are about to delete all personally identifiable information held for this contact. Please ensure that all outstanding tasks/interactions with this person have been completed before continuing with the deletion process”
  2. If the contact can be deleted you will be asked to confirm that you wish to delete this contact by entering the Deletion Code provided
  3. The record will be deleted and you will be returned to the Home screen
  4. If the contact fails this rule you will receive a notification advising you which of the rules are preventing the contact from being deleted and the Delete option will be disabled
  5. Click Cancel to return to the previous screen

 

Batch Deletions

Batch deletion is available to users with permission to use this function and is a separate permission to the Individual Deletions permission.  

Batch deletion is available from lists of Applicants, Vendors and Landlords.  

These lists can be filtered to provide a list of contacts that you want to delete.  

The Applicants list has two filters for Viewings in last x months and Matches within in last x months.  

  1. Once the filtered list has been prepared click on Special Actions
  2. Delete Selected Applicants (Landlords, Vendors or Contacts depending upon the type that you are deleting)
  3. The list will be checked against the Deletion Rules set by you in System Configuration and the Active record checks
  4. A message will be displayed telling you how many of the selected records have failed the deletion rules and these will not be deleted
  5. Only the current page will be checked and actioned, the default number of records displayed per page is 50, this can be altered from the Records per page setting in the bottom left corner of the page. It can be set to:
  • All
  • 10
  • 50
  • 100

It can also be set in the Refine Search settings.

  1. You can navigate to the next page to process the next 50 by clicking on the First, Previous, Next or Last controls (<< < Displaying 2 of 7 pages > >>) on the bottom right of the page

  1. Upon entering the confirmation code correctly the eligible records will be added to the list of records pending deletion, and you will be returned to the list of any remaining records, including those records that could not be deleted because they failed the rules set
  2. A notification email will be automatically sent to designated members of staff, advising them of any batch delete requests, to help protect your business from accidental or malicious deletion of your client details
  3. The list of users receiving this email is set in Manage Users

 

Pending Deletions

When Batch Delete is actioned the records are not immediately deleted

Each record is anonymised so that no personal information can be viewed and it is added to the list of records pending deletion

Attempting to search for the record that you deleted will display a no record found message

Only personal details are deleted, remaining records will not display personal details, instead, it will show Contact Deleted

This list can be managed by users with the relevant user permission, allowing 7 days for the record to be restored, if need be.

This will allow a period of time for you to ensure that the record was not accidentally or maliciously deleted.  

If no action is taken within 7 days the record will be irrevocably deleted.  

 

Manage Deletions

The ability to Manage Deletion Requests is set in Manage Users click here 

This function is available from the Admin menu and will provide a list of all records pending deletion.  

The list can be searched by Contact Name or Email Address and can be filtered by date deleted and deleted by you or any user, allowing you to locate a record or records that have been set for deletion.  

The list can also be sorted by Name, Deleted By or Removal Date by clicking on the arrows at the top of that column, clicking on the arrow again will reverse the order.  

You can select all records by ticking the box on the left of the header column and individually select or deselect a person by ticking the box to the left of their name.  

Clicking on Revert Selected will take you to the Confirm Revert Deletion Request screen.  

Once the correct Confirmation Code has been entered the selected records will be restored to their original status.  

A single deletion can be reverted by clicking on Revert at the end of the row for that person.  

Warning - Records can only be reverted for up to 7 days from the date of the deletion request, at which point they will be irrevocably deleted.

 

Existing Actions
Existing Deletions

As you will be aware the previous delete process did not fully delete the personal details of the contact, elements of that remained.  

Therefore in order to comply with the GDPR deletion requirements, Jupix has fully deleted the remains of these records. You will not need to take any further action.  

Existing Archives

The existing records that are already archived are not affected. If you wish to delete records that are already archived you will need to action those separately.  

Deleting Other Entities

Deleting a property was the only way to delete the owner's record.  

However now that an owner can be deleted from the contact record there is no need to delete the property, in fact you will probably want to keep the details for comparison purposes.

Therefore the Delete Property button has been removed from the Property/Special Actions menu, the Archive Property option still remains.  

 

Configuration Settings


User Permissions

User Permissions have been added to allow you to control who can:

  • Delete an Individual record
  • Batch Delete records
  • Manage Deletion requests
  • Receive email notification for Bulk Deletions

These permissions are set in Admin/Manage Users and will be off for all users, by default.  

Deletion Rules

We have introduced 3 rules which can be applied to prevent you from accidentally batch deleting records that you may not wish to delete, in order to comply with legal and regulatory requirements.

These are explained below.

HMRC requires accounting records be retained for 6 years from the end of the Financial Year. 

You will be able to turn the HMRC Rule off from Admin/System Configuration/System Settings/Person Deletion Settings. 

When the rule is turned on you will be able to set the retention period to 6 or 7 years. 

The default setting is 7 years to take account of varying financial year end dates.  

The rule will be checked for individual and batch deletions and will prevent the deletion of a person's records where there are accounts entries of less than the number of years set by you.  

Anti Money Laundering regulations require Estate Agents to carry out identity checks when they establish a business relationship with a client.   

These checks must be retained for 5 years from the date that the business relationship has come to an end.  

The AML Rule can also be turned off from Admin/System Configuration/System Settings/Person Deletion Settings.  

When turned on the rule will be checked for individual and batch deletions and this will prevent the deletion of a person's records where there has been a business relationship within the last 5 years.  

A business relationship starts with an Owner when an Appraisal is won and with an Applicant when an Offer or Application is made.  

The business relationship ends with a Vendor or Applicant when the Offer has been Withdrawn/Declined or the Sale is Completed or Fallen Through.  

It ends with a Landlord or Applicant when the Application has been Withdrawn/Offer Declined/References Unsuccessful, or the Tenancy has Finished or after the last Ledger entry, whichever is the later.  

The Property Ombudsman Service requires its members to keep clear and full written records of all transactions for a period of 6 years and produce them when required by the Ombudsman.  

The TPOS Rule is also turned off from Admin/System Configuration/System Settings/Person Deletion Settings. 

When turned on the rule will be checked for individual and batch deletions and this will prevent the deletion of a person's records where there have been any transactions within the last 6 years.  

In Jupix if any of the following applies within the last 6 years the record falls under the TPOS rule and will not be deleted.  

  • For any Contact, Owner or Applicant record, if there are any entries in the Notes tab
  • For a Potential Owner, once an Appraisal has been booked.
  • For an Applicant
  • Any Property Matches recorded
  • Any viewings booked, without a match
  • Any offer or application received, without a viewing
  • For a Supplier
  • A works order has been linked to the Supplier
  • An Invoice has been added to their Ledger
  • If a Solicitor, they have been linked to Vendor or Applicant record

The above rules will be turned on by default, if they are turned off you will see an advisory message of the effect of this and potential consequences. EG:

 

Viewings and Matches
Many agents will want to keep details of viewings carried out and property details issued during the period they were instructed, to facilitate any Private Sale clause periods they may have in their Terms of Business.  

Therefore two further rules have been introduced for use with individual and batch deletions, Months Since Last Viewing and Months Since Last Match.  

They will both be 0 by default but you are able to set these from 0 to 240 months.  

Any changes made to the rules listed above will be recorded and can be viewed by clicking on the History button at the top of the page. 

This record can also be downloaded as a .csv file.  

Active record checks

A number of checks are made before a record can be deleted, to ensure that it is no longer active, so that, for example, you are not left with entries on your dashboard that you are no longer able to clear. 

These include:

  • There should be no Appraisals Pending or Carried Out - Pending Follow Up
  • Vendors can’t have a Property Instructed On/Off Market or Completed - On Market
  • Landlords can’t have a Property Instructed On/Off Market or Let - On Market
  • There should be no Sent Details not Followed Up for Matches
  • There should be no Pending Viewings or Viewings Requiring Follow Up
  • There should be no Pending Offers
  • There should be no Current or Exchanged Sales
  • There should be no Applications with an Offer Pending or References Pending
  • Tenancies must be Withdrawn, Terminated or Finished
  • A person can’t be deleted if linked to an open Maintenance job, it must be Cancelled or Invoice Paid
  • Leases should be Declined, Terminated or Expired
  • Solicitors can’t be deleted if linked to an Active Sale
  • To Do's must be Completed

 

If a record can’t be deleted because it failed any the active record checks you can review the details for that person, and complete any outstanding tasks. 

You should then be able to delete the record, subject to passing any the other rules turned on.  

If you are unable to delete a record you will still have the option to archive it.  

 

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