1. Overview
This Data Retention Schedule describes how long CareSwaps, LLC retains each category of data and how we dispose of it when the retention period ends. Retention periods reflect the longest applicable legal obligation, including HIPAA (45 CFR § 164.530(j), six years minimum), IRS recordkeeping (seven years for tax records), the federal Anti-Kickback Statute (documentation retained indefinitely to support a defense), and Colorado consumer-protection recordkeeping.
Legend: PHI Protected Health Information · PII Personal Identifying Information · OPS Operational data (de-identified) · FIN Financial/billing · LEGAL Legal and compliance.
2. Protected Health Information (PHI)
| Data Category | System | Retention | Disposal |
|---|
| PHI Resident identifiers, DOB, POA status, care needs | Google Sheets (Master PHI DB) | 6 years after subscription end (HIPAA minimum) | Secure Deletion w/Audit Log |
| PHI Jotform intake submissions | Jotform HIPAA Gold | 6 years after submission | Secure Deletion w/Audit Log |
| PHI Outbound email with PHI | Paubox (encrypted) · Gmail (under Workspace BAA) | 6 years | Secure Deletion w/Audit Log |
| PHI PHI access / audit logs | Google Apps Script + Workspace audit | 6 years minimum | Secure Deletion w/Audit Log |
HIPAA Minimum: 45 CFR § 164.530(j) requires covered entities and business associates to retain HIPAA-related documentation for six years from the date of its creation or the date when it last was in effect, whichever is later. CareSwaps applies this minimum to all PHI records and all PHI-related audit logs.
3. Personal Identifying Information (PII — Non-PHI)
| Data Category | System | Retention | Disposal |
|---|
| PII Subscriber account (name, email, state) | Google Workspace / Airtable | Life of subscription + 3 years | Secure Deletion |
| PII Support tickets and communications | Google Workspace (Gmail) | 3 years after resolution | Secure Deletion |
| PII Marketing / waitlist signups (pre-subscription) | Airtable · Make.com | 2 years from signup or opt-out | Secure Deletion |
4. Operational Data (De-identified — No PHI)
| Data Category | System | Retention | Disposal |
|---|
| OPS Swap IDs, match status, timestamps | Airtable | 6 years (consistent with HIPAA audit trail) | Secure Deletion |
| OPS Facility roster (business info, not PHI) | Airtable | Life of contract + 6 years | Secure Deletion |
| OPS Automation execution logs (Make.com) | Make.com | 90 days (rolling) | Automated Purge |
| OPS Website analytics (GA4, aggregated, IP-anonymized) | Google Analytics | 14 months | Automated Purge |
5. Financial and Billing Data
| Data Category | System | Retention | Disposal |
|---|
| FIN Invoices, receipts, subscription history | Stripe · Accounting | 7 years (IRS) | Secure Deletion |
| FIN Refund records, chargebacks, disputes | Stripe | 7 years | Secure Deletion |
| FIN Tax returns and supporting documents | Accounting | 7 years | Secure Deletion |
6. Legal, Regulatory, and Compliance Records
| Data Category | System | Retention | Disposal |
|---|
| LEGAL Executed BAAs with facilities | Google Drive (secured) | Term + 6 years | Secure Deletion |
| LEGAL Executed Client Subscription Agreements | Google Drive | Term + 6 years | Secure Deletion |
| LEGAL Executed Technology Services Agreements | Google Drive | Term + 6 years | Secure Deletion |
| LEGAL Anti-Kickback Statute compliance documentation | Google Drive | Indefinite (to support defense) | No automatic disposal |
| LEGAL Breach investigation records | Google Drive | 6 years after incident close (HIPAA minimum) | Secure Deletion w/Audit Log |
| LEGAL Complaint records (customer, OCR, AG) | Google Drive | 6 years | Secure Deletion |
| LEGAL Policies, procedures, audit reports | Google Drive | 6 years after each version retired | Secure Deletion |
7. Disposal Methods
| Method | Description | Applies To |
|---|
| Secure Deletion w/Audit Log | Record is cryptographically erased or fully deleted from primary and backup systems; disposal action is recorded with actor, timestamp, and record ID. | PHI and PHI-adjacent records |
| Secure Deletion | Record is deleted from primary and backup systems. Disposal recorded at the aggregate level. | PII, FIN, LEGAL (non-PHI) |
| Automated Purge | System-level purge governed by the service provider's retention controls (e.g., Make.com 90-day log retention, GA4 14-month data retention). | Operational logs, analytics |
| Standard Deletion | Standard user-initiated deletion where formal audit logging is not required. | Marketing / top-of-funnel records |
| No Automatic Disposal | Records retained indefinitely to support regulatory defense. Reviewed annually. | AKS documentation |
8. Legal Holds
When CareSwaps receives notice of litigation, a governmental investigation, a subpoena, or a regulatory audit, the records implicated are placed under a legal hold. Retention and disposal schedules are suspended for those records until the hold is released in writing by the Privacy Officer or outside counsel.
9. Contact
Questions about retention or disposal: privacy@careswaps.com · (970) 306-7131 · CareSwaps, LLC, 2519 S. Shields St., Suite 1K PMB 1159, Fort Collins, CO 80526.