# Retention & Secure Disposal

**Organization:** {{COMPANY_LEGAL_NAME}}
**Document owner:** {{POLICY_OWNER_ROLE}}
**Approved by:** {{APPROVER_NAME}}, {{APPROVER_TITLE}}
**Version:** {{VERSION}} · **Effective:** {{EFFECTIVE_DATE}} · **Next review:** {{REVIEW_DATE}}
**Classification:** Internal

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## 1. Purpose

Data we no longer need is a liability, not an asset. This policy makes sure {{COMPANY_LEGAL_NAME}} keeps {{DATA_TYPES}} only as long as it is genuinely needed and then disposes of it so it cannot be recovered by anyone unauthorized, including data held in {{CRITICAL_SYSTEMS}} and subject to {{GEO_SCOPE}} residency rules.

## 2. Scope

This covers all electronic and physical records, backups, and media the organization creates or holds. It applies to the {{LOCATION}} workforce, to systems in {{CRITICAL_SYSTEMS}}, and to managed {{DEVICE_TYPES}} that store or cache {{DATA_TYPES}}.

## 3. Policy statements

### 3.1 Retention schedule

We maintain a schedule that lists each record type alongside its retention period, owner, and primary storage location, noting {{GEO_SCOPE}} residency where it applies. Each personal-information category is mapped to a minimum and maximum retention period tied to the purpose for which it was collected. The schedule is reviewed at least annually and whenever new {{INDUSTRY}} data types appear.

### 3.2 Periodic data review

Owners run a review (automated or manual) at least quarterly to find data that has passed its retention period in {{CRITICAL_SYSTEMS}}, collaboration repositories, and on managed {{DEVICE_TYPES}}. Records flagged for deletion are queued for disposal within thirty days, and we log the review dates and outcomes and track queued deletions through to completion.

### 3.3 Secure disposal methods

For electronic data we use secure-wipe utilities or crypto-erasure by destroying encryption keys, confirming the outcome for cloud stores in {{CRITICAL_SYSTEMS}}. Physical media is cross-cut shredded or handled by a certified destruction vendor. Every disposal event is documented with its date, data category, method, and location, and destruction certificates are retained and access-restricted where used.

### 3.4 Backup and archive controls

Backups and archives follow the same retention timelines as production data. Backups are encrypted, and we verify that they age out on schedule or are re-encrypted when keys rotate, noting backup residency in {{GEO_SCOPE}} and storage in {{CRITICAL_SYSTEMS}}. We periodically test that backups expire and restore correctly and that keys and access remain protected.

### 3.5 Compliance measurement

A quarterly check confirms that only a small fraction of records sit past their retention period and that disposal logs are complete. For teams larger than {{EMPLOYEE_COUNT}}, we expand the sample and add random checks across {{CRITICAL_SYSTEMS}} and managed {{DEVICE_TYPES}}.

## 4. Roles and responsibilities

| Role | Responsibility |
|---|---|
| Executive sponsor | Accountable for the program; approves this policy |
| {{POLICY_OWNER_ROLE}} | Maintains this policy and its procedures |
| Managers | Enforce the policy within their teams |
| All personnel | Comply; report issues promptly |

## 5. Compliance and exceptions

Over-retained or improperly disposed records are escalated to senior management and remediated promptly. A legal hold or contractual obligation may override the schedule; when it does, we document the reason, a review date, and any impact on {{DATA_TYPES}} residency in {{GEO_SCOPE}}. Exceptions require documented risk acceptance by {{APPROVER_TITLE}} and are time-limited and reviewed.

## 6. Review

This policy is reviewed at least annually and when significant change occurs. We update the schedule and tooling after audits, incidents, or regulatory change, reflecting {{INDUSTRY}} requirements and any updates to {{GEO_SCOPE}} obligations.

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*Aligned to ISO/IEC 27001:2022. {{COMPANY_LEGAL_NAME}} is not affiliated with or endorsed by the relevant standards body; full standard text is copyrighted and is not reproduced here.*