P4.2 Retaining personal information
Personal information is retained in line with privacy objectives. Points of focus: it is kept no longer than needed for the stated purposes unless law requires otherwise; and it is protected from erasure or destruction during its retention period.
Source: SOC 2 (2017 Trust Services Criteria), P4.2. 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 SOC 2 (2017 Trust Services Criteria) in the compliance library.
These are criteria, not controls: you design controls that meet them, and which criteria are in scope follows the categories your report covers (Security always; Availability, Confidentiality, Processing Integrity and Privacy only if chosen). A Type 2 report tests that the controls operated across the period, so the evidence asked for is samples across that period, not one copy.
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
- Evidence of automated retention enforcement · Data governance / DLP tooling
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Retention schedule for personal information categories · Policy repository / GRC workspace
- Legal hold procedure · Policy repository / GRC workspace
First move
Common gaps auditors find
- Personal data retained indefinitely
- Retention schedule not implemented in systems
- Premature deletion undermining legal obligations
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 sheetP4.1 Limiting use to identified purposes · P4.3 Securely disposing of personal information