This policy defines the organizational requirements for data retention and secure disposal throughout the information lifecycle. It ensures compliance with legal and regulatory obligations like GDPR and ISO 27001 by enforcing retention schedules and irreversible disposal practices.
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Comply with Data Minimization: Adhere to GDPR's core principle of storage limitation by retaining data only as long as necessary and securely disposing of it afterward.
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Establish Defensible Schedules: Maintain a Master Data Retention Schedule (MDRS) that maps data categories to retention periods based on legal, contractual, and business needs.
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Reduce Your Attack Surface: Minimize risk, operational cost, and legal exposure by systematically purging expired data from live systems, backups, and archives.
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Ensure Secure & Irreversible Disposal: Implement auditable disposal procedures compliant with NIST SP 800-88, including cryptographic erasure and physical destruction.
Read Full Overview
The Data Retention and Disposal Policy is a comprehensive framework designed to manage the lifecycle of information assets effectively, ensuring compliance with legal and regulatory requirements such as ISO 27001, GDPR, and NIST standards. This policy outlines the organizational responsibilities for retaining data in accordance with classification levels and securely disposing of it when no longer required. By enforcing clear retention schedules and disposal methods, the policy supports legal compliance, prevents data hoarding, and reduces the risk of breaches.
What's Inside
- Purpose and Scope
- Roles and Responsibilities
- Master Data Retention Schedule
- Data Lifecycle Management Rules
- Secure Disposal Procedures
- Legal Hold Requirements
- Risk Treatment and Exceptions
Built for Leaders, By Leaders
This policy was authored by a security leader with 25+ years of experience deploying and auditing ISMS frameworks for global enterprises. It's designed not just to be a document, but a defensible framework that stands up to auditor scrutiny.
Authored by an expert holding:
Framework Compliance
🛡️ Supported Standards & Frameworks
This product is aligned with the following compliance frameworks, with detailed clause and control mappings.
| Framework | Covered Clauses / Controls |
|---|---|
| ISO/IEC 27001:2022 | Clauses 6.1.3, 8.1 |
| ISO/IEC 27002:2022 | Controls 5.10, 5.12, 5.30, 5.33 |
| NIST SP 800-53 Rev.5 | AU-11, MP-6, SI-12, PL-2 |
| EU GDPR | Articles 5(1)(e), 17, 32 |
| EU NIS2 | Article 21(2)(a-e) |
| EU DORA | Articles 5, 9 |
| COBIT 2019 | DSS01, DSS05, MEA03 |
Part of a Complete ISMS Toolkit
This policy is one of 37 documents in our complete toolkit. When implemented as a set, our framework helps you achieve comprehensive compliance across major standards.
100%
ISO 27001
95%
NIST
88%
NIS2
75%
DORA
70%
GDPR
Related Policies
This policy is closely linked with the following documents to enforce a coherent data governance model.
Access Control Policy (P4)
Ensures only authorized individuals access data during its retention period.
Asset Management Policy (P12)
Tracks assets requiring scheduled disposal throughout their lifecycle.
Data Classification & Labeling Policy (P13)
Guides decisions that influence retention duration and disposal methods.
Backup and Restore Policy (P15)
Defines retention and disposal for backup media and replicated data.
Cryptographic Controls Policy (P18)
Supports cryptographic erasure for disposal and encryption during storage.
About This Policy
The Clarysec Data Retention and Disposal Policy establishes a formal, auditable framework for managing your information throughout its entire lifecycle. It provides clear, classification-based retention schedules to ensure you meet legal, regulatory, and business requirements without accumulating unnecessary data. This is critical for complying with the data minimization and storage limitation principles of GDPR.
By implementing this policy, you can systematically reduce your data footprint and associated attack surface. It mandates secure, irreversible disposal methods aligned with NIST SP 800-88, protecting your organization from data leakage from retired media. This policy is a cornerstone of effective data governance, providing a defensible process for auditors and demonstrating a mature approach to information security.
