Data Retention and Disposal Policy - SME

The Data Retention and Disposal Policy - SME (Policy P14S) is crafted specifically for Small and Medium Enterprises (SMEs), recognizing the constraints and unique responsibilities that such organizations face. This policy is fully adapted for SMEs, evident from the involvement of the General Manager as policy owner, without the assumption of specialized roles such as SOC or CISO, while ensuring compliance with leading frameworks such as ISO/IEC 27001:2022, GDPR, and related regulations. The primary purpose of this policy is to set clear, enforceable rules for retaining and securely disposing of information, ensuring records are kept only as long as mandated by law, contracts, or business need. After these requirements are fulfilled, information must be irreversibly destroyed. The policy addresses the importance of minimizing legal exposure and operational risk by preventing unauthorized or redundant data retention. It also highlights the benefits of well-governed retention and disposal for audit readiness, reduced costs, and improved system performance. For SMEs, the policy serves as a practical means to responsibly manage both digital and paper data assets, regardless of IT team size. The comprehensive scope includes all types of records, business documents, operational logs, financial files, personal data, and applies to every storage medium, from local drives and cloud systems to paper storage and backups. All employees, contractors, and third-party providers who handle organization data are bound by this policy. The policy covers every stage of the data lifecycle, from creation through to secure disposal or destruction. A key feature is the clear delineation of roles and responsibilities. The General Manager provides approval, ensures alignment with legal and business risk, and handles exceptions and legal holds. Designated Data Owners are assigned by data category and are responsible for classification, determining retention periods, and authorizing deletions; they also support audit processes. The IT Support Provider or Internal IT Lead is tasked with configuring systems for retention rules, disposal logging, and secure erasure, including for backups and archives. Employees and contractors are expected to comply with the policy, avoid improper retention, report orphaned data, and only use approved systems for data storage. The core governance requirements revolve around maintaining a detailed Retention Register listing record categories, assigned periods, disposal methods, legal justification, and data owners. This register must be reviewed annually or upon relevant legal or business triggers. Disposal methods are selected based on data classification, using secure procedures such as cross-cut shredding, cryptographic erasure, or physical destruction of media. Legal holds are expressly detailed, once applied, they prevent deletion regardless of the scheduled retention period and require monthly review. The policy also mandates staff training and annual refreshers to ensure awareness. Exceptions are tightly controlled, with processes for documentation, approval, review, and justifiable expiration. Enforcement mechanisms include regular audits, spot-checks, and strict consequences for violations, up to and including contract termination or regulatory reporting in case of personal data mishandling. Ultimately, this policy ensures that an SME can operate in a legally compliant, auditable, and resource-efficient manner, even when advanced IT security roles are not present. It is purpose-built to align with ISO/IEC 27001:2022 and privacy laws, giving SMEs a robust foundation for data lifecycle management without unnecessary complexity.