Free policy template

ISO 27001

Data Retention & Secure Disposal Policy

How long each kind of record is kept, who owns that decision, and how the record is destroyed once the period ends.

Download the Markdown

Free and ungated, no email required. The full template is below and in the download. Authored in Keel’s own words and aligned to ISO 27001; replace the {{PLACEHOLDER}} tokens with your details.

What is a data retention policy?

A data retention policy says how long your organization keeps each kind of record, who owns that decision, and how the record is destroyed once its period ends. It turns "we clear things out eventually" into a schedule somebody is accountable for.

Four things sit inside one: a retention schedule listing each record type with its period, owner and storage location; a periodic review that finds data past its date; a disposal method for electronic media and for paper; and the rule that backups and archives age out on the same timeline as production data.

Auditors ask for it because data you no longer need still widens every breach you might have, and a period nobody wrote down cannot be shown to have been followed. The template below is the policy Keel ships in-product.

How to use it

  1. Download the template. Grab the Markdown file, or copy the full text from this page.
  2. Fill in the placeholders. Replace every {{PLACEHOLDER}} token (company name, owner, approver, dates, version) with your details.
  3. Tailor it to how you operate. Adjust the statements so they describe what your organization actually does. A policy you do not follow is worse than none.
  4. Approve and publish. Have an accountable owner approve it, set an effective date and a review date, and share it where staff can find it.
  5. Keep it current. Review on the schedule you set (or when things change), and keep evidence that it is followed. In Keel this is tracked for you.

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


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.


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.

Common questions

How long should we keep data?

There is no single number, and a template that gave you one would be wrong. The period comes from the purpose the data was collected for, plus any legal, tax or contractual tail on top of it. Section 3.1 of this template is where you record the period per record type and the reason behind it.

Is a data retention policy the same as a retention schedule?

The policy sets the rules, names the owner and says how disposal happens. The schedule is the table of record types and periods the policy points at. Many organizations keep the schedule as a separate appendix so a new record type can be added without re-approving the whole policy.

What does secure disposal mean in practice?

For electronic data, a secure wipe or crypto-erasure, which destroys the encryption keys so the remaining ciphertext cannot be read. For paper, cross-cut shredding or a certified destruction service. Either way the event is logged with its date, data category, method and location, because disposal you cannot show is disposal an auditor cannot accept.

What about data under a legal hold?

A legal hold or a contractual obligation overrides the schedule, and the template says so rather than pretending otherwise. When it happens you record the reason and a date to review it, so the hold does not quietly become permanent retention.

Manage this policy in Keel

Keel ships this template in-product, fills the placeholders, maps it to your controls, and tracks approvals and reviews, so the policy stays live evidence, not a file in a drive. Start free.