From the perspective of an organization’s responsibility as a data controller, personal data retention is a critical process that defines how long personal data is processed. This applies not only to traditional paper-based records but, more importantly, to the organization’s IT infrastructure. The process also includes managing access permissions related to the scope of data processing.
Key Principles of Personal Data Retention
A fundamental principle of personal data retention is the implementation of mechanisms that determine:
- Whether personal data should be retained, and
- For how long it can be processed within the organization.
Retention periods should align with the business objectives for which the data was originally collected, while also complying with legal requirements established by applicable regulations.
Methods of Data Retention Management
The data retention process can be executed in different ways, depending on:
- The organization’s data processing methods,
- The level of expertise, and
- The available tools used for retention management.
Retention management can be manual or automated, with the latter relying on IT system configurations that enforce data deletion mechanisms.
The Role of IT Systems in Data Retention
To ensure efficiency and compliance, IT systems should be designed to:
- Define retention periods for different categories of personal data, and
- Automatically remove data once it reaches the end of its retention lifecycle.
Challenges of Automated Data Retention
For organizations managing multiple IT systems and complex data flows, implementing an automated personal data retention process presents a significant challenge. To ensure compliance, efficiency, and seamless execution of retention policies, it is advisable to engage specialized external providers.
How to Implement an Automated Personal Data Retention Process?
Implementing an automated personal data retention process requires comprehensive analytical and verification activities aimed at selecting the optimal IT tool. These activities include:
- Analysis and assessment of existing solutions and procedures related to personal data retention within the organization.
- Verification of personal data processing in selected IT resources to evaluate how personal data is managed.
- Assessment of IT systems and applications to determine the presence of (or potential for implementing) automated modules that support the personal data retention process.
- Analysis of backup systems to evaluate their impact on personal data retention and identify how they can be leveraged within the process.
- Review of existing retention policies and procedures to detect gaps, identify necessary improvements, and enhance overall compliance.
- Designing and implementing an automated personal data retention management process, tailored to the organization’s specific needs, IT system administrators, application managers, and business data owners.
By conducting these steps, organizations can ensure that their automated retention process is both efficient and compliant with regulatory requirements while minimizing risks associated with data over-retention or premature deletion.