Data handling policy

Data handling policy. What we collect, how we move it, where it lives, and when it is destroyed. Written plainly, because a policy no one reads protects no one.

This policy governs client data in every Momentum engagement.

It applies to all personnel, subcontractors, and systems involved in delivery, and covers employee records, payroll data, benefits information, financial data, and any personally identifiable information transferred to us in the course of work.

Placeholder for legal review: this page summarizes operating practice. Final policy language should be confirmed by counsel before publication.

Six commitments that apply to every file we receive.

• Collection — We request the minimum data required for the defined scope. Additional fields require a documented change of scope agreed with the client.
• Transfer — Data moves through secure managed file transfer or client-provided secure channels. Email attachments, consumer file sharing, and removable media are prohibited.
• Storage — Client data is held in an access-controlled environment segregated by client, in named regions, with encryption at rest and logged access.
• Use — Data is used only to deliver the contracted engagement. It is never used for benchmarking, marketing, model training, or resale.
• Subcontractors — Any third party with access is bound by equivalent written terms, and clients are notified before a subcontractor is engaged.
• Retention and Destruction — Working copies are destroyed within thirty days of engagement close unless a longer period is contractually required. Certification of destruction is available on request.

You can ask us what we hold, at any time.

Clients may request an inventory of data in our possession, request early destruction, or request return in an agreed format. We respond to written requests within ten business days.

Questions about how we handle your data?

Our compliance team will walk through the policy and answer specifics for your engagement. Contact compliance →

Also on our main site: www.momentumdatasolutions.com/data-handling-policy