UC journal and data retention policy

This has been touched on previously, e.g. here and here, but I thought I’d revisit it (post-GDPR, if that makes a difference).

We have a query from someone who recently moved from a single-person UC award to a couple award. As might be expected, they lost access to their previous journal through the website. A subject access request yielded the DWP case notes for the single person claim, but not the UC journal. On the client chasing it up, they were told that DWP had provided all “the information they are able to generate to meet a Customer request”, which I think is ambiguously phrased. Does anyone have a view on whether the journal is likely to still be retrievable, e.g. if they had to respond to an appeal, might DWP be able to access it still?

DWP’s general data retention policy is to keep ‘supporting records’ for 14 months after the end of the award. By contrast, (according to this page), ‘ephemeral records’ are kept for 4 weeks.

I would have thought a UC journal would be a ‘supporting record’? Are they complying with their own retention policies?

I note that in this FOI response, DWP say:

A claimant’s Universal Credit account cannot be accessed indefinitely. If a claimant is reclaiming within 6 months, they can reclaim and access their Universal Credit records. Anything outside of the 6 months period; claimants will have to start the process of claiming again.

A claimant’s Universal Credit account will not be open for 14 months; our data retention period is 14 months. The reclaim period is 6 months.