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What Is a Data Retention Policy? Key Things To Know

  • In short: A data retention policy is a written set of rules that defines what data your organization keeps, how long it’s kept, where it’s stored, who is responsible for it, and how it’s archived, anonymized, or deleted at end of life. Retention policies are required (or strongly implied) by GDPR, HIPAA, SOX, PCI DSS, and CCPA/CPRA, and a documented policy is a standard ask in SOC 2, ISO 27001, and most enterprise security questionnaires.

Your business has to keep federal tax returns and supporting documents for up to seven years and OSHA accident forms for five years. Many legal documents need to be retained indefinitely. This confusing tangle of storage requirements emphasizes why every business needs a policy for data retention. What is a retention policy, and how do you create one?

What Is a Retention Policy for Data?

What is a data retention policy? Here's what you should know.

A data retention policy is a written set of rules that explains your organization’s approach to storing data. A good retention policy also explains how you should store data and who is responsible for protecting, reviewing, and deleting it. It should also explain what happens to data at the end of its lifecycle, including archiving, deletion or anonymization.

Retention policies cover a wide range of data types and documents:

  • Emails and other work communications
  • Employment contracts and worker records
  • Business financials and tax documents
  • Names, shipping addresses, purchase histories, and other customer details
  • Payment card information
  • Visitor information gathered from website cookies

Companies usually have different retention procedures for each type of data. For example, businesses generally store confidential financial documents differently from email communications.

Why Is a Data Retention Policy Important?

A retention policy is a document with two main audiences: company personnel, who need clear guidelines for managing and storing data, and everyday consumers, who need to understand how their data is handled and protected. This policy has several different purposes.

Maintain and Improve Business Operations

Many types of business records are critical for the smooth operation of your business. Manufacturers depend on production records to monitor process efficiency and improve product quality. 

B2B companies rely on client records, contracts, purchase orders, and invoices to deliver the right items at the right price. Reviewing employee data can also help businesses identify ways to improve productivity and efficiency.

Comply With Government and Industry Regulations

Depending on your industry, there are strict requirements regarding data collection, storage, protection, and deletion. Here are some of the most common:

  • General Data Protection Regulation: GDPR follows a storage-limitation principle, which means personal data shouldn’t be kept longer than necessary for the purpose it was collected.
  • Payment Card Industry Data Security Standard: PCI DSS guidelines cover data storage and encryption requirements for merchants.
  • Health Insurance Portability and Accountability Act: HIPAA requires covered entities to protect Protected Health Information for as long as it’s maintained, while certain HIPAA documentation must be retained for six years.
  • Sarbanes-Oxley Act: SOX and related SEC recordkeeping rules require retaining certain audit and financial records, including audit records that auditors must keep for seven years.
  • California Consumer Privacy Act: CCPA/CPRA gives California residents privacy rights and requires businesses to justify retention and avoid keeping personal information longer than reasonably necessary and proportionate for disclosed purposes.

In many cases, creating and implementing a comprehensive data retention policy is a cornerstone of compliance. Violating the rules can carry sizable penalties.

Protect Your Data Against Cyber Threats

Secure data storage is an important part of cybersecurity best practices. This includes regular data backups and cloud storage. Data loss prevention practices can help your company bounce back in the event of a ransomware attack or natural disaster. 

Your data retention policy should include procedures to safeguard information against unauthorized access, such as:

  • Encryption
  • Multi-factor authentication
  • Employee restrictions
  • Firewalls
  • Other robust network defenses

Keeping unnecessary data longer than needed can also increase the damage a breach can cause.

Inform Customers and Website Visitors

Many regulatory frameworks require your business to explain to users in detail what type of data you collect, how you use it, how long you store it, and who can see it. Creating a data retention policy helps you meet these requirements.

Displaying your retention policy on your website also helps you build customer trust. If you take a consumer-friendly posture toward data retention — such as encrypting client data or never selling information to third parties — highlight those details proudly. Write your policy in simple language that anyone can understand.

Meet Legal Requirements for Discovery

If you’re engaged in a lawsuit, you often legally need to retain certain documents for a long time. Your policy should explain how the company:

  • Preserves potentially relevant electronically stored information
  • Pauses routine deletion when a legal hold applies
  • Keeps records accessible for review and production

Including these details in your data retention policy can help you avoid discovery violations.

What Should a Data Retention Policy Include?

Here's what an organization's data retention policy should include.

The design of retention policies depends on the size of your organization and the scope of your data processing. That said, every policy should cover the following elements:

  • List of Data Categories: Types of data covered by the policy, such as financial records, company emails, legal documents, customer data, and contracts
  • Retention Periods: The length of time each type of data should be kept
  • Responsibilities: The people or teams responsible for storing, reviewing, and managing each type of data
  • Storage Locations: The approved places where data may be stored, such as on-site systems, cloud platforms, or Exchange Online
  • Backups: The rules for backup frequency, backup storage, and backup retention
  • Disposal: The process for archiving, deleting, or destroying data after the retention period ends
  • Consumer Privacy Practices: The standards for handling customer data, including payment card information

A corporate data retention policy doesn’t have to name specific documents (e.g., balance sheets); however, it should provide all of the details necessary for departments to store the required records securely and in harmony with regulatory requirements.

Why a Retention Schedule Matters

Many businesses also include a simple retention schedule or matrix that lists the following:

  • Data category
  • Legal or business basis
  • Retention period
  • Storage location
  • Owner and disposal method 

A retention schedule like this gives each department a practical way to follow the policy instead of guessing what to do next. Finance can quickly see how long to keep tax and payment records, and HR can confirm rules for employee files. 

The schedule is especially useful for contract management because it helps teams track signed agreements, renewal dates, notice periods, and disposal rules. IT can also manage where data lives, when backups apply, and when records should be archived or deleted. Having that kind of clarity helps reduce over-retention, lowers compliance risk, and makes audits, legal holds, and day-to-day data management much easier to handle.

How Do You Create a Data Retention Policy?

Use your data retention policy as a reference manual for guiding your organization’s data handling procedures. A comprehensive policy can strengthen your cybersecurity defenses and help you avoid costly mistakes.

Set Compliance Goals

If your organization must comply with GDPR, SOC 2, ISO 27001, or other frameworks, build your data retention policy around the necessary regulatory, privacy, and cybersecurity guidelines. For example, SOC 2 audits have extensive evidence-gathering requirements.

Collaborate With Company Stakeholders

Customize your data retention policy by getting advice from business professionals in your organization. Speak with legal, financial, IT, and accounting teams about recommended data retention periods for related documents.

Follow Data Security Best Practices

The risk of data breaches means your organization’s data retention posture should follow up-to-date cybersecurity practices:

  • Zero trust and least privilege for employee access
  • Client-side encryption and cloud storage encryption
  • Encryption in transit
  • Centralized data storage

Data backups are an essential part of any modern retention policy. Regularly create redundant backups at multiple storage locations, including an air-gapped security copy for ransomware protection. Review the policy at least annually and whenever you add new systems, expand into new markets or take on new regulatory obligations.

How Compyl Helps You Build and Manage a Data Retention Policy

Compyl can help an organization develop an effective data retention policy.

The first step in creating a data retention policy is identifying your organization’s information assets. A common mistake is overlooking the importance of records such as company emails for business continuity after a cyberattack. Platforms like Compyl make it much easier to visualize, organize, and centralize your organization’s document flow and data storage. Define your retention policy efficiently and effectively with Compyl’s advanced features now.

Data retention policy FAQs

A data retention policy is a written set of rules that defines what data your business keeps, how long it's kept, where it's stored, who's responsible for it, and how it's archived, anonymized, or deleted at end of life. Most regulated industries are required to have one to demonstrate compliance with privacy and security laws.

 Retention periods vary by data type and jurisdiction. Common minimums include seven years for federal tax records, six years for HIPAA records, five years for OSHA accident reports, and seven years for SOX audit workpapers. Personal data under GDPR must be kept "no longer than necessary," meaning each data type needs a defined, documented retention period.

Data retention is the policy that defines how long data must be kept and what happens at end of life. Archiving is one of the actions that policy can require — moving inactive data into long-term, lower-cost storage where it remains accessible for legal, regulatory, or historical purposes. Retention is the rule; archiving is one execution method.

Yes, in practice for all three. GDPR Article 5(1)(e) requires personal data to be kept no longer than necessary, with documented justification. HIPAA §164.316(b)(2) requires six years of records retention. SOX §802 requires seven years for audit workpapers. SOC 2 and ISO 27001 also expect a documented retention policy as a baseline control.

A complete data retention policy should include the data types covered, the retention period for each, the legal or business basis for that period, storage and security requirements, access controls, the disposal method (deletion, anonymization, archiving), assigned owners for each data class, exception handling, and a defined review cadence — typically annual or after any major regulatory change.

Ownership is usually shared. The Chief Compliance Officer or Data Protection Officer owns the policy itself, IT and Security own enforcement and storage, Legal owns regulatory interpretation, and individual department heads own day-to-day adherence for their data. In smaller organizations, the GRC lead or CISO typically owns all four roles until headcount allows specialization.

The risks are regulatory fines (GDPR penalties can reach 4% of global revenue), failed audits in SOC 2, ISO 27001, HIPAA, and PCI DSS, increased breach exposure from over-retained data, higher e-discovery costs in litigation, and lost enterprise deals — most security questionnaires explicitly ask for a retention policy as a prerequisite to vendor approval.

At minimum once a year, and immediately after any of the following: a new regulation taking effect (e.g. a state privacy law), a major change in the data the business collects or stores, an M&A event, a security incident, or a finding from an internal or external audit. Treat the review date as a tracked control, not an afterthought.

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