7.4.7 Retention
The organization must not retain personal data longer than the purposes for which it is processed require, developing and maintaining retention schedules that take account of legal, regulatory and business requirements a
4
artefacts
0
held by a system
1
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
- Review record keeping the schedule current with legal change · Data governance / DLP tooling
governing documentDocuments that govern the control
- Retention schedule covering every category of personal data, with the period and its justification · Policy repository / GRC workspace
- Evidence the schedule is enforced, not merely published · Policy repository / GRC workspace
- Documented risk based decisions where legal, regulatory and business requirements conflicted · 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
- Schedule published and never enforced, so the actual retention is indefinite
- Single retention period applied across all data because the longest legal requirement was adopted for everything
- Conflicts resolved informally in favour of retention, with no risk assessment or decision record
- Backups, archives and analytics copies outside the schedule
- Schedule written by records management and never reconciled to what systems actually do
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 sheet