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Supersedes 0071. The iOS privacy manifest and App Tracking Transparency rules of 0071 (decisions 3 and 4) carry forward. Classification is ADR 0134.

Context

0071 (Proposed) named privacy obligations without the export format, the erasure process or the retention defaults. The owner’s answers DA5, DA6, SC10 and CP2 (mem L531–533, L552, L832, 2026-10-20) fix them.

Decision

  1. Export (DA5). A data export is a signed zip, available for seven days.
  2. Erasure (DA5). An erasure saga removes a person’s data and issues receipts through the compliance service.
  3. Offboarding (DA5). A tenant leaving has a 30-day grace period.
  4. Retention defaults (DA6). Soft-deleted records are kept 30 days. Archives are kept until the tenant is deleted. AI thread data is kept 90 days. A tenant may change a default within bounds.
  5. Documents (SC10). A sub-processor list, a data-subject request runbook, a record of processing, and a data processing agreement, all available now.
  6. Laws (CP2). GDPR, the UAE and KSA PDPL, and the children’s data rules apply now. HIPAA and FERPA come later.
  7. Classification. Field classes are set by ADR 0134.

Consequences

  • A tenant can see its own export before it leaves, so offboarding has no surprise.
  • Retention is a default that a tenant can tighten, so the platform does not hold data longer than the contract needs.

Enforcement

planned — the retention jobs (Prunable, ADR 0134) run on schedule; the export and erasure sagas are covered by end-to-end tests.

Alternatives

  • Retention set per tenant with no default: rejected; a default protects tenants who do not configure it.

Supersedes and sources

Supersedes: 0071. Sources: owner answers DA5, DA6, SC10, CP2 (stackra-decisions-2026-10-19.md L531–533, L552, L832, 2026-10-20). Closes gap C23.