What evidence do auditors commonly ask for on A.1.4.8 Retention?

Retention schedule covering every category of personal data, with the period and its justification; Evidence the schedule is enforced, not merely published; Documented risk based decisions where legal, regulatory and business requirements conflicted; Review record keeping the schedule current with legal change.

What is the most common gap auditors find on A.1.4.8?

Schedule published and never enforced, so the actual retention is indefinite

ISO/IEC 27701:2025 · Annex A Table A.1 PIMS controls for PII controllers

`A.1.4.8` Retention

The organization must not keep personal data for longer than its processing purposes need. It must draw up and maintain retention schedules that reflect legal, regulatory and business requirements; where those requirements pull in different directions, it must make a business decision grounded in a risk assessment, document it and enter it in the relevant schedule.

Source: ISO/IEC 27701:2025, A.1.4.8. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open ISO/IEC 27701:2025 in the compliance library.

artefacts

held by a system

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. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Documented risk based decisions where legal, regulatory and business requirements conflicted · Regulator portal / correspondence
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

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

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

A.1.4.7 Temporary files · A.1.4.9 Disposal