Data Retention Policy
Effective Date: [Insert Date]
Reviewed Date: [Insert Date]
Policy Owner: [Department/Person responsible]
Version: 1.0
1. Purpose
This policy establishes guidelines for the retention, storage, and disposal
of data within [Organization Name] to ensure compliance with applicable
laws, regulations, and internal standards, such as ISO 27001, GDPR, and
CCPA.
2. Scope
This policy applies to:
All types of data, including personal, financial, operational, and
employee records.
Data stored in any medium (physical or electronic), including
databases, file systems, emails, and paper records.
All employees, contractors, and third parties handling the
organization’s data.
3. Roles and Responsibilities
Data Owner: Responsible for defining retention periods for specific
types of data.
Data Protection Officer (DPO): Monitors compliance with the
retention policy and applicable regulations.
Information Security Team: Ensures secure storage and deletion
of data according to this policy.
Employees: Follow the policy and report any non-compliance or
data incidents.
(Aligned with ISO 27002: A.5.2 on roles and responsibilities.)
4. Policy Statements
4.1 Data Classification
Data will be classified as Public, Internal, Confidential, or
Highly Confidential to determine retention and disposal methods
(ISO 27002: A.5.12 on data classification).
Personal data will be treated according to the privacy regulations,
such as GDPR.
4.2 Data Retention Schedule
Retention periods must align with legal, regulatory, or business
requirements.
Data retention must be limited to what is necessary to fulfill the
intended purpose. Below are sample categories and retention
periods:
Data Type Retention Period Reason
Employee 7 years after Legal requirement (HR
Records termination compliance)
5 years after last Business and legal need
Customer Data
interaction (GDPR)
Financial Regulatory requirement (Tax
10 years
Records laws)
1 year from the event Internal audits and
Incident Logs
date investigations
Backup Data 30 days Operational requirement
4.3 Exceptions
If there are ongoing investigations, legal cases, or audits, relevant
data must be retained until the matter is resolved, even if the
standard retention period has passed.
5. Data Storage
All data must be stored securely according to the organization’s
data classification and access control policies.
Encrypted storage will be used for confidential or highly sensitive
information.
6. Secure Disposal and Deletion
Upon the expiration of the retention period, data will be securely
deleted or destroyed to prevent unauthorized access.
o Electronic Data: Overwritten using secure erasure tools.
o Physical Data: Shredded or incinerated.
Ensure that all disposal processes are documented and auditable
(ISO 27002: A.5.33 on protection of records).
7. Data Subject Requests (Personal Data)
Data subjects have the right to request erasure of their personal
data, subject to legal and contractual obligations (aligned with
GDPR).
All requests must be logged and processed within [Insert Days]
days.
8. Backup Retention
Backup data should follow a separate retention schedule.
Backups should be encrypted and retained only for operational
continuity, with a maximum retention of [Insert Duration] (aligned
with ISO 27002 A.5.30 on ICT readiness for business continuity).
9. Monitoring and Compliance
Compliance with this policy will be monitored through regular
internal audits.
Non-compliance may result in disciplinary action and, if applicable,
notification to regulatory authorities (ISO 27002: A.5.36 on
compliance monitoring).
10. Policy Review and Updates
This policy will be reviewed annually or when significant changes
occur, such as new regulations or business operations.
All changes must be approved by [Department/Committee].
11. Contact Information
For questions regarding this policy, please contact:
Data Protection Officer: [Insert Name and Contact Information]
Approval:
Authorized by: [Insert Approver’s Name and Title]
Data Retention Policy
Effective Date: [Insert Date]
Reviewed Date: [Insert Date]
Policy Owner: [Department/Person responsible]
Version: 1.0
1. Purpose
This policy outlines the principles and guidelines for the retention,
storage, and secure disposal of data at [Organization Name]. It ensures
that data is retained for appropriate periods to meet business, legal, and
regulatory requirements while protecting personal and sensitive data.
2. Scope
This policy applies to:
All data types including personal, operational, financial, and
employee data.
All employees, contractors, and third parties with access to
the organization’s data.
All data storage media, including digital and physical formats.
3. Roles and Responsibilities
Data Owner: Defines retention periods and ensures data is
managed in accordance with this policy.
Data Protection Officer (DPO): Monitors compliance with the
policy and data protection laws (e.g., GDPR).
Information Security Team: Ensures that appropriate technical
controls are in place to protect and securely delete data.
All Employees: Follow the data retention policy and report any
breaches or non-compliance issues.
(Aligned with ISO 27002: A.5.2 on roles and responsibilities.)
4. Data Classification and Retention Periods
Data will be classified based on its sensitivity and usage, and retained
only for the necessary period to fulfill business or legal obligations. Below
are examples of retention periods:
Data Type Retention Period Reason
Employee 7 years after
Legal compliance with labor laws
Records termination
5 years after last Regulatory requirement (GDPR,
Customer Data
interaction CCPA)
Financial
10 years Tax and audit regulations
Records
1 year from the Internal audits and
Incident Logs
incident date investigations
Operational need and regulatory
Email Records 2 years
review
Backup Data 30 days Operational continuity
Any exceptions to these periods must be documented and approved by
the Data Owner or DPO.
5. Secure Storage and Access Control
Data will be stored securely in accordance with the access control
policy (ISO 27002: A.5.15 on access control).
Sensitive data will be encrypted in transit and at rest.
Access to data will be restricted to authorized personnel only.
6. Data Deletion and Secure Disposal
Digital Data: Deleted securely using methods such as data wiping
tools or encryption key destruction.
Physical Data: Shredded or incinerated to prevent unauthorized
access.
Disposal processes will be logged to ensure auditability and
compliance with ISO 27001: A.5.33 on protection of records.
7. Backup Retention
Backup copies will follow a separate retention policy to ensure
business continuity. Backups will be encrypted and retained for a
maximum of 30 days unless otherwise specified (ISO 27002: A.5.30
on ICT continuity).
8. Data Subject Rights
Right to Erasure: Individuals can request the deletion of their
personal data in compliance with GDPR/CCPA requirements, subject
to legal obligations.
Right to Access: Individuals can request access to their data at
any time.
All requests must be processed within 30 days of receipt.
9. Monitoring and Compliance
Internal audits will be conducted regularly to ensure compliance
with the Data Retention Policy and applicable laws (ISO 27002:
A.5.36 on compliance monitoring).
Non-compliance may result in disciplinary action and, if applicable,
notifications to regulatory authorities.
10. Policy Review and Updates
This policy will be reviewed annually or whenever significant changes
occur, such as new regulations or operational changes. Any changes must
be approved by [Insert Department/Committee].
11. Policy Exceptions
Any exceptions to this policy must be documented and approved by the
Data Owner and Data Protection Officer (DPO).
12. Contact Information
For questions regarding this policy, please contact:
Data Protection Officer: [Insert Name and Contact Information]
Approval:
Authorized by: [Insert Approver’s Name and Title]
