1. Purpose
This policy outlines the principles and procedures for retaining, managing, and securely disposing of data collected, processed, and stored by {Organization Name}. The purpose is to ensure compliance with applicable regulations, including GDPR, CCPA, or other relevant laws, and to safeguard sensitive information while supporting operational and legal requirements.
2. Scope
This policy applies to all employees, contractors, third-party service providers, and any other entities handling data on behalf of {Organization Name}. It covers all types of data, including but not limited to:
- Personal Data (e.g., customer information, employee records).
- Financial Data.
- Operational Data.
- Marketing Data.
3. Data Retention Principles
- Compliance with Legal Requirements:
- Data must be retained for the minimum period required by applicable laws and regulations.
- Where retention periods are not legally specified, data shall be retained based on business and operational needs.
- Data Minimization:
- Only data necessary for defined purposes will be collected and stored.
- Retention Period:
- Retention periods shall be defined based on:
- Legal or regulatory obligations.
- Contractual requirements.
- Operational needs.
- Retention periods shall be defined based on:
- Secure Storage:
- Data will be stored securely using appropriate technical and organizational measures to prevent unauthorized access, modification, or loss.
- Timely Disposal:
- Data exceeding the retention period will be securely deleted, destroyed, or anonymized.
4. Retention Periods
| Data Category | Retention Period | Legal Basis or Justification |
|---|---|---|
| Customer Data | {e.g., 7 years after contract end} | {e.g., Contractual/Legal Requirement: GDPR Article 5(1)(e)} |
| Employee Records | {e.g., 6 years post-employment} | {e.g., Employment laws, tax regulations} |
| Financial Records | {e.g., 7 years} | {e.g., Tax compliance, legal audits} |
| Marketing Data | {e.g., 2 years from collection} | {e.g., Legitimate Interest, Consent Revocation} |
Note: Retention periods must align with specific organizational and regulatory requirements.
5. Responsibilities
- Data Owners: Ensure proper classification and compliance with the retention schedule.
- Data Protection Officer (DPO): Monitor adherence to this policy, provide guidance, and oversee secure disposal.
- IT Department: Implement technical safeguards for secure storage and deletion of data.
6. Data Disposal Procedures
- Data identified for disposal must be securely deleted or destroyed using methods appropriate for the data’s sensitivity level (e.g., encryption, shredding, or overwriting).
- A disposal log must be maintained, documenting:
- Date of disposal.
- Type of data disposed.
- Method of disposal.
- Responsible personnel.
- Third-party disposal services must comply with this policy and execute confidentiality agreements.
7. Review and Updates
- This policy will be reviewed annually or as required by changes in regulations, business practices, or operational needs.
- Updates to retention periods or processes will be communicated to all relevant stakeholders.
8. Compliance and Monitoring
Failure to adhere to this policy may result in disciplinary action, regulatory penalties, or reputational damage. Regular audits will be conducted to ensure compliance with this policy and applicable regulations.
9. Contact
For questions about this policy, contact:
- Data Protection Officer (DPO): [Contact Information]
- Compliance Team: [Contact Information]
