Essential Transcript Data Deletion for Compliance (Early Adopter)

Essential Transcript Data Deletion provides organizations the ability to automatically delete User Transcript Data based on a defined retention period for inactive users in accordance with various regulations, such the EU GDPR and the Right to be Forgotten policy.

Important: To enable this enhancement, contact Global Customer Support.

Once enabled, administrators can activate this feature by going to Admin > Tools > Learning > Learning Preferences > Feature Activation Preferences. In the Feature Activation section, for the Activate Learning Transcript Deletion Mechanism for Compliance area, click the Activate button. The following applies once activated:

  • Data deletion respects the retention rule set at the Legal Entity Organizational Unit (OU) which users are part of at the time of the deletion.
  • Automatic deletion applies to the transcript of inactive users who are terminated.

Deleted Data

The following Essential Transcript Data is deleted:

Transcript Peripheral Data Transcript Core Data
Training Certificates​ ​ Transcript data for the transcript of the User (LO id, LO Title, subject, version etc.)​
​ Attachments (OJT/ Express Class)​ Transcript status (not started, pending approval, in progress, completed, etc.) and eventual scores​
Comments (entered when assigning, approving/ denying, marking complete, updating transcript, exempting, removing, etc.)​ Dates (assignment date, due date, completion date, etc.)​
Evaluations ​ Active, Completed, Archived , Removed Transcript
Reporting  

Time-based Data Deletion

The following applies to time-based data deletion:

  • Time-based deletion occurs automatically after a certain period. The execution itself is triggered on daily basis for Inactive User’s Learning Transcript Data based on the User’s termination date.
  • The user must belong to a Legal Entity OU and must be inactive. Users should be assigned to the Legal Entity before their termination date.
  • Data is erased permanently from the database and cannot be recovered. Data is also removed from the Reports.
  • Customers must enable User data anonymization/ deletion prior to Time based activation for Transcript for each Legal Entity OU.
  • Before opting-in for this process Customers must request via GCS one-time historical data cleanup for previously anonymized/ deleted users if they already use User anonymization/ deletion mechanism in their portal. ​

Frequently Asked Questions (FAQs)

Q: Do we need to perform a copy down to stage before enabling the feature for testing?​

A: Yes, it’s a best practice to perform copy down to stage before enabling the new feature in the stage portal for testing on the most updated data available in the Production portal.​

Q: Will Transcript Deletion preserve statistics?​

A: No, deletion does not preserve statistics.

Q: Will Transcript Data related to xAPI be deleted?​

A: Yes, only xAPI records on the User transcript level would be deleted. Data under xAPI statement viewer/ LRS is out of scope of this release.​

Q: Do we need to enable User Data anonymization/ deletion before Transcript?​

A: Yes, it is mandatory to enable User Data anonymization/ deletion configuration with Legal Entity OUs/ settings/ retention period before opting for the time-based Transcript Data Deletion.​

Q: Do we need to perform historical transcript data deletion for previously anonymized users prior to time-based transcript data activation?​

A: Yes, it is mandatory to perform this one-time activity to avoid load on the system for first time enablement.

Q: Is it possible to restore data that has been deleted through the transcript data deletion functionality?

A: No, the purpose of deletion is that the data is gone, and Customers nor Cornerstone longer process or possess a person’s transcript data. Be very careful and diligent when choosing retention periods, and to do proper UAT before deploying in production.​

Q: What is the process for Customer to opt for automated time-based transcript data deletion?​

A: First, the Customer must activate user data anonymization/ deletion mechanism, if already leveraging. Next, request historical data cleanup for previously anonymized users via GCS case/ work order. Finally, request the enablement of the feature activation preference visibility on the UI in the same case to toggle the preference for time-based.​

Q: What will happen to the User Transcript and other screens post the data is deleted?​

A: User's will have an empty transcript with data deleted from active, completed, archived and removed tabs as well as relevant reports and system areas like Session Roster Page, Curriculum Administration > View Users, etc.

Q: What happens if a person (by error) belongs to multiple Legal Entity OUs at the same time?​

A: Transcript data generated during an overlapped Legal Entity window will have both Legal Entity tags associated and will be deleted based on the shortest retention period​

Q: What happens if there is API Integration in place for Transcript Data?​

A: API only returns transcript data for active users.​

Implementation

This functionality is off by default. Contact Global Customer Support to enable.