Data retention policy
Last Updated: February 5, 2025
This document describes the length of time VA.gov systems may retain user data for the purposes of processing a request from the user.
Introduction
The VA.gov platform and the applications implemented on it are not intended to be long-term personal data repositories; in government parlance, they are not “systems of record.” Rather, VA.gov is intended to be a front-end interface for interaction with other VA systems, a.k.a. “downstream systems.”
Generally speaking (with the exception described below), our policy is that data on VA.gov pertaining to individuals, either data provided by users for submission to downstream systems or data retrieved from downstream systems to provide to users, may not be stored within VA.gov for longer than 60 days. This includes not only the structured data submitted by the user and stored by the application, but also any derived data such as the PDFs generated from the structured data.
Applications are expected to include automated data deletion processes. Reliance on manually executed data deletion processes is not permitted. Note that the VA Forms Library implements automated expiration of form data but not of derived data such as saved PDFs.
In-flight data exception
Data provided by users for submission may be retained for longer, in particular, for up to 60 days after they have been successfully submitted to the intended downstream system. That is, the 60-day retention clock is extended by any delays in successfully submitting the data.
There are four categories of submission delays with different mitigation strategies and expectations, described below. In all four categories, the maintainers of the impacted VA.gov application are required to take active steps to mitigate the issue, including notifying the user about the delay and its cause, and to ensure that the data are eventually either successfully submitted or deleted. VFS teams may not retain data indefinitely under any circumstances. The appropriate steps necessary to mitigate submission failures must be taken.
Incomplete data from user
If a user starts filling out a form, or starts some other process whose progress is saved by the application, but does not complete the process, then the data may be retained for up to 60 days past when the user is required to restart the process.
For example, let’s say a user has filed an Intent to file and thus they have an entire year to fill out a form. All the data the user inputs into that form may be saved for one year, plus an additional 60 days.
If there is no deadline for submitting a particular form, i.e., by policy its data could be retained forever, then a 1-year deadline should be assumed.
Downstream system error
If VA.gov fails to submit user data to a downstream system because of a problem with the downstream system, then the data may be retained for up to 60 days after the problem is fixed.
VA.gov application error
If VA.gov fails to submit user data because of a bug in our application and we can fix the issue without any further input from the user, then the data may be retained for up to 60 days after the bug has been fixed and the data has been successfully submitted.
If, even after we fix the bug, previously provided data cannot be successfully submitted without further input from the user, e.g., because the bug corrupted data in a way that we cannot fix without input from the user, then the data may be retained for up to 60 days after the user is notified that their input is required to resolve the problem.
User error
If incorrect or missing data provided by a user prevents downstream submission, then the data may be retained for up to 60 days after the user is notified that their input is required to correct and resubmit the data.
Furthermore, instances of user error should be analyzed to determine if additional validation can be added to the application to prevent similar errors in the future. For example, if an online form allows the user to make an error that prevents downstream submission, then that is a bug that should be addressed.
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