GDPR: Legal and compliance settings

Prerequisites

Administrator access is required to configure Legal and compliance settings, including GDPR, data retention, Terms of use, and the Legal notice.

Administrator access to Legal and compliance controls:

Approving or rejecting user data deletion requests
Activating data retention and defining the retention period
Publishing and translating the Terms of use, and uploading the Legal notice

Contact your Administrator if your role does not have the permissions needed to complete a step in this article.

Overview

Legal and compliance is where administrators manage the platform's data protection and legal obligations — processing requests to delete personal data, defining a Data Protection Officer (DPO), automating data retention, and publishing the Terms of use and Legal notice shown to users.

The Legal and compliance workflow follows these main stages:

1Process pending user data deletion requests
2Define the DPO and, optionally, activate automated data retention
3Configure the help and contact links shown in the platform footer
4Publish the Terms of use and manage its translations
5Upload and activate the Legal notice document

Some of these settings trigger automatic platform behaviour — such as scheduled deletions and email notifications to administrators — which is explained in the relevant sections below.

Key elements

Data deletion request: a user-initiated request to delete their personal data, which must be approved or rejected within 30 days.
DPO (Data Protection Officer): the named contact responsible for data protection, shown alongside the privacy policy link.
Data retention period: a platform-wide rule that automatically schedules inactive user data for deletion.
Accessibility footer links: optional Help and Contact links displayed in the platform footer for all users.
Terms of use: the platform's terms, translatable into every active platform language.
Legal notice: an uploaded document made available to users, separate from the Terms of use.

What's changing — October 2026 release

The following updates to automated account deletion are scheduled for release in October 2026. This article already reflects the new behaviour in the sections below; anything not mentioned as new stays as previously documented.

Full scope coverage: the retention scope selector (Activated users / Suspended users / Both) will fully cover whichever statuses are selected — including suspended accounts, which today are not reliably covered even when checked (Section III).
Existing configurations are unaffected: until an administrator actively changes it, scope stays at Activated users only, the current default.
New "Users scheduled for deletion" view: admins get a direct, exportable list of accounts due for deletion in the next month, with identifier, status, and scheduled date, from the same GDPR screen (Section III).
Learners get an advance warning: before an account is deleted for inactivity, the learner is warned in time to prevent it — for example by logging back in (Section VII). This replaces today's behaviour of no advance notice in the automatic flow.
Deletion means anonymisation: deleted accounts are anonymised rather than hard-deleted — they no longer appear anywhere on the platform, and no personal data is retained afterwards, including in the event history and logs (Sections II and VII).
Scheduled deletions run at a fixed time: processing happens on the scheduled date at 3:00 AM UTC (Section III).

IAccess settings IIData deletion IIIGDPR & retention IVAccessibility links VTerms of use VILegal notice VIINotifications

I — Access Legal and compliance settings

Go to: Settings > Legal and compliance.

The page opens with five collapsible sections:

User data deletion — pending and scheduled requests to delete a user's personal data.
GDPR — DPO contact details and automated data retention.
Accessibility — Help and Contact links shown in the footer.
Terms of use — the platform's Terms of use and its translations.
Legal notice — an uploaded legal document.

Result: Clicking a section header expands it. Only one section needs to be open at a time to make and save changes.

II — Manage user data deletion requests

Go to: Legal and compliance > User data deletion > Manage.

On the Pending deletion requests tab, review each row: user, username, role, and request date.
Use the Search field, or the Role, Perimeter, and Request date filters, to narrow the list.
Approve or reject a single request with the row-level check or cross icons in the Actions column, or process every visible request at once with APPROVE ALL REQUESTS or REJECT ALL REQUESTS.

Result: Approving a request anonymises that user's personal data — the account no longer appears anywhere on the platform, and no personal data is retained afterwards, including in the event history and logs. Rejecting a request removes it from the pending queue without deleting any data. The Scheduled deletion tab separately lists users due for automatic deletion under the retention rule (Section III).

30-day compliance window

Pending deletion requests must be processed within 30 days to meet GDPR obligations. The platform does not auto-approve requests after this window — processing remains a manual administrator action.

Anonymisation is permanent — there is no reactivation

Whether triggered manually or automatically (Section III), an approved deletion request results in permanent anonymisation. There is no reactivation mechanism: if a user logs back in after their retention deadline has already passed, their account is not restored.

III — Configure GDPR and data retention

Go to: Legal and compliance > GDPR.

Enter the DPO Name and DPO Email of the person responsible for data protection.
Optionally, paste a Privacy policy link.
Check Activate data retention period to enable automatic deletion scheduling.
Select a Data retention period: A month, 1 year, 2 years, 5 years, or Custom.
Under Impacted users, check Activated users and/or Suspended users. Starting October 2026, this scope selector fully covers whichever statuses are checked. Existing configurations default to and remain on Activated users only until an administrator changes it.
Click Save.

Result: 30 days before a user's calculated deletion date, they are listed on the User data deletion page under Scheduled deletion (Section II).

How the retention date is calculated

The countdown is based on the last login date for activated users, and the suspension date for suspended users. A user who keeps logging in never reaches the retention threshold, since each login resets the countdown.

How the nightly job works, in detail

Once activated, a scheduled task runs every night. For each organisation with the setting enabled, it selects every user whose last login date (the lastLoginDate field) falls before the configured cut-off, and creates a data deletion request for each one. These requests then feed into the same User data deletion queue used for manually submitted requests (Section II). Selection relies solely on lastLoginDate — no other field is taken into account. Once scheduled, processing runs on the scheduled date at 3:00 AM UTC.

Accounts with no login date are never picked up

Accounts with no recorded last login date — for example, historical accounts imported from a previous LMS, or users who have never logged in — are not included in the automatic process. The selection rule is last login date ≤ cut-off date, and a null value never satisfies this condition. There is no fallback to the account creation date or any other field, so these accounts are systematically excluded.

This is the main GDPR attention point: since the mechanism relies exclusively on last login date, accounts that have never logged in are not covered by automatic deletion and will remain in the database indefinitely. Compliance with the storage limitation principle for this population is not guaranteed by this feature — it requires a separate manual purge process. We recommend identifying this population of inactive or never-logged-in accounts and defining a dedicated procedure alongside activating automated retention.

IV — Set up accessibility footer links

Go to: Legal and compliance > Accessibility.

Check Activate help link in footer to display a Help link pointing to your internal help centre.
Enter the destination URL in Link for the help page.
Check Activate contact link in footer to display a Contact link.
Enter the address that receives contact emails in Contact email.
Click Save.

Result: Enabled links appear in the footer for all platform users. The Help link opens the URL provided; the Contact link opens the user's email client addressed to the contact email, giving users first-level support.

V — Configure Terms of use and translations

Publish the Terms of use

No standard template is provided

The platform does not supply a standard Terms of use template. Content must be drafted and configured by your organisation, in line with your own internal data protection policy.

Go to: Legal and compliance > Terms of use.

Check Activate terms of use.
Select the source Language (the platform's default language is pre-selected).
Write or paste the content in the Terms of use rich text editor.
Click Save.

Translate the Terms of use

Click Manage translations.
Click Add language, choose a language from the dialog, then click Add.
Open the newly added language to enter and save its translated text.

Result: Each added language appears in the translations table with its own Accessibility and Translation progression status. Users see the Terms of use in their platform language once a translation is completed and saved.

How the Terms of use are shown to users

The Terms of use are presented to the user via a pop-up window the first time they log in. If the Terms of use are activated after users already have accounts, the pop-up appears the next time each affected user logs in.

VI — Add a Legal notice document

Go to: Legal and compliance > Legal notice.

Check Activate legal notice.
Under Legal notice document, drag and drop your file into the upload zone, or click it to browse your computer.
Click Save.

Result: The uploaded document becomes the platform's active legal notice. The maximum file size is 500 MB.

Uploading replaces the previous document

A new upload replaces the previously active legal notice. Keep a copy of the outgoing document outside the platform if you need to retain a record of it.

VII — Understand automated deletion notifications

When a user requests deletion of their own data

Administrators receive an email titled "You have received a Request to Delete an account on your platform," identifying the requesting user and linking directly to the User data deletion page (Section II) so the request can be processed.

Monthly scheduled-deletion recap

If data retention is activated (Section III), administrators also receive a monthly recap email listing accounts scheduled for automatic deletion. This template can be reviewed from Emails > Edit email templates, under the {userCount} scheduled for deletion email, where the Subject and body can be edited, variables such as {scheduledDeletionsUrl} and {userCount} inserted, and changes verified with TEST TEMPLATE before clicking SAVE.

Email	(#232) {userCount} scheduled for deletion
Triggers	Monthly upcoming-deletions recap
Note	Email sent monthly to administrators when user accounts are scheduled for deletion

Result: Both notifications are sent only to users with the Administrators role — never to the learner whose data is affected.

Learners get an advance warning

A learner will receive a warning before their account is deleted for inactivity, in time to prevent it — for example, by logging back in. This is separate from the manual flow, where a notification already exists when the learner initiates their own deletion request.

Audit trail after a deletion

Each deleted account writes exactly one anonymised entry in the event history, in the form: "A user was deleted after Y years of inactivity." This entry contains no identifiers — no name, username, or other personal data is retained anywhere after deletion, including in the event history and logs.

FAQ & Troubleshooting

Issue: The pending deletion request count keeps growing.
Solution: Requests must be processed manually within 30 days; the platform does not auto-approve them. Assign an administrator to review the User data deletion page regularly, or use APPROVE ALL REQUESTS / REJECT ALL REQUESTS to clear the queue in bulk.

Issue: Users report they can't see the Terms of use in their own language.
Solution: Check Manage translations to confirm the language has been added and its translation completed and saved. An added language with no completed translation will not display for users.

Issue: The footer Help or Contact link isn't visible to users.
Solution: Confirm the corresponding checkbox (Activate help link in footer or Activate contact link in footer) is checked in the Accessibility section, and that Save was clicked after the change.

Issue: A user was deleted, but an administrator didn't expect it.
Solution: Check whether Activate data retention period is enabled in the GDPR section. If so, the deletion was likely automatic, based on the configured retention period and the user's inactivity.

Issue: The Legal notice document won't upload.
Solution: The file exceeds the 500 MB size limit. Compress the document or split it, then re-upload a file under the size limit.

Issue: A batch of legacy or never-logged-in accounts is not being caught by automatic retention.
Solution: This is expected: automatic retention selects only accounts with a recorded last login date before the cut-off. Accounts with no last login date (for example, historical imports) are never selected and have no fallback rule. Identify this population separately and process it through a manual deletion request instead.
Can we recover a user's data after a deletion request is approved?
— No. Approving a deletion request permanently deletes and anonymises the user's data. Reject the request instead if you are not certain.

Can we set different retention periods for different user roles?
— The retention period applies platform-wide once activated. You can, however, choose whether it applies to Activated users, Suspended users, or both.

Who receives the monthly scheduled-deletion recap email?
— Only users with the Administrators role receive this email.

Is the Legal notice document shown in multiple languages?
— The Legal notice is a single uploaded document. Multi-language management, as described in Section V, applies to the Terms of use text only.

What happens if we deactivate data retention after it's already scheduled deletions?
— Unchecking Activate data retention period and saving stops new deletions from being scheduled going forward. Confirm with your Administrator whether previously scheduled deletions are also cleared, as this was not covered in the reviewed settings.

If a user logs back in after their retention deadline has passed, is their account restored?
— No. There is no reactivation mechanism. Once a deletion is processed, it is permanent, regardless of whether the user attempts to log in afterwards.

Does the platform provide a standard Terms of use template?
— No. The Terms of use content must be authored by your organisation to reflect your own policy; the platform only provides the activation, editing, and translation tools described in Section V.

Is the learner warned before their account is automatically deleted under the retention rule?
— Yes: the learner will receive a warning before an automatic deletion for inactivity, in time to prevent it (for example, by logging back in). A notification already exists today when the learner initiates the deletion request themself.

Can automated deletion be scoped to suspended accounts as well as activated ones?
— Yes, the scope selector in the GDPR section fully covers whichever statuses are checked — Activated users, Suspended users, or both. Existing configurations default to, and remain on, Activated users only until an administrator changes it.

Are deleted accounts fully erased, or anonymised?
— Anonymised. The account no longer appears anywhere on the platform, and no personal data is retained afterwards, including in the event history and logs. Each deletion writes one anonymised, identifier-free entry to the event history.

Can administrators refuse data deletion requests in batch, not just one by one?
— Yes. Use REJECT ALL REQUESTS on the User data deletion page to refuse every visible pending request at once, or the row-level cross icon to refuse a single request (Section II).
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