SOC 2 P4.2: Privacy - Retention of Personal Information

Define retention periods for every category of personal information. Factor in legal minimums (some regulations mandate how long you must keep certain records), contractual obligations, genuine business necessity, and the privacy principle of keeping data for the shortest useful period. Document the rationale for each period and get sign-off from legal and privacy stakeholders. Build a retention schedule that maps each data category to its retention period, the trigger that starts the clock (account closure, contract end, collection date), the disposal method, and who is responsible. Make this schedule accessible to all teams that handle personal data. Automate enforcement wherever possible. Configure your databases and applications to flag or delete records past their retention period. Use data lifecycle management tooling that works across multiple systems. For data that cannot be automatically purged, schedule regular manual reviews and assign clear ownership. Address every location where personal data lives. Production databases are the easy part. What about backups, staging environments, analytics warehouses, email archives, shared drives, and third-party SaaS tools? Map them all and extend your retention enforcement to each one. Backups are the most commonly overlooked. Consider anonymisation as an alternative to deletion. If historical data has analytical value, strip out personal identifiers instead of deleting entire records. But verify that the anonymised data cannot be re-identified by combining it with other data sources - pseudo-anonymisation is not the same as true anonymisation. Audit your own compliance regularly. Check that data past its retention period is actually being disposed of across all systems. Look for orphaned data in decommissioned systems, old backups, and forgotten third-party accounts. Document findings and fix gaps promptly.