DSP-16 Data Retention and Deletion
Manage data retention, archiving and deletion against business requirements and applicable law, so data is neither kept longer nor destroyed sooner than allowed.
4
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Evidence retention periods are enforced technically · Data governance / DLP tooling
- Deletion records at end of retention · Data governance / DLP tooling
governing documentDocuments that govern the control
- The retention schedule by data type with the requirement behind each period · Policy repository / GRC workspace
- Legal hold procedure and its interaction with deletion · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Retention schedule published with no technical enforcement
- Data retained indefinitely because deletion was never built
- Legal hold not accounted for, so data under hold is deleted
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetDSP-15 Limitation of Production Data Use · DSP-17 Sensitive Data Protection