Data Retention & Disposal Policy

Requirements for retaining organizational data and ensuring secure disposal when no longer needed.

Data Retention & Disposal

Field Value
Document ID POL-010
Classification Internal
Owner CTO (interim CISO)
Effective Date April 2026
Review Cycle Annual

This policy defines the guidelines for retaining and securely disposing of company data in compliance with applicable legal, regulatory, and business requirements. Data is maintained only for as long as necessary and securely disposed of when no longer required.


Scope

This policy applies to all employees, contractors, vendors, and any other individuals responsible for handling company data across all formats, including digital and physical records.


Data Retention Requirements

  • Data must be retained for the minimum duration necessary to fulfill legal, regulatory, and business requirements.
  • Retention periods for different categories of data are defined based on applicable laws, industry standards, and operational needs.
  • Personal data must be stored only for as long as required for its original purpose, after which it must be deleted or anonymized in compliance with applicable data protection regulations.

Retention Periods by Data Category

Data Category Retention Period Notes
Personal Data (Customer) Only as long as necessary for processing purposes Subject to data subject rights and applicable regulations
KYC Data As per applicable financial regulatory requirements Includes identity documents and verification records
Transaction & Order Data As per applicable financial regulatory requirements Includes all financial transaction records
Employee Records 5–7 years In compliance with applicable labor laws
Financial Records 7 years In accordance with applicable tax regulations
Contracts & Agreements Duration of contract + 7 years Based on business and legal requirements
Audit Logs 1–3 years Depending on regulatory and security requirements
Support & Communication Logs 1–2 years For service quality and dispute resolution
Application Logs As defined in the Log Management Standard Cross-reference: Log Management (STD-012)

Account Deletion

  • When a user requests account deletion, personal data is anonymized (soft delete).
  • After the applicable regulatory retention period, data is permanently deleted (hard delete).
  • This ensures compliance with both user rights and regulatory retention obligations.

Secure Data Disposal

When data reaches the end of its retention period, it must be securely disposed of to prevent unauthorized access or data breaches.

  • Digital data must be permanently deleted using industry-standard methods, such as cryptographic erasure or secure overwriting.
  • Cloud-hosted data must be disposed of through proper deletion of storage resources, removal of access controls, and application of lifecycle policies to ensure data is not retained beyond the required period.
  • Physical documents must be shredded or securely destroyed in compliance with document disposal regulations.
  • Storage devices containing sensitive data must be degaussed, physically destroyed, or securely wiped before disposal or reuse.

Backup Data

  • Data in backups follows the same retention periods as the source data.
  • Backup lifecycle policies are configured to automatically expire and remove backups beyond the defined retention period.

Third-Party Data

  • Vendors and partners handling company data on our behalf are required to follow the same data retention and disposal standards.
  • Data disposal obligations are included in vendor agreements and contracts.

Disposal Verification

  • Disposal of sensitive data must be verified and confirmed by the responsible team.
  • A disposal log is maintained as evidence for compliance and audit purposes.

Compliance and Monitoring

  • Regular audits are conducted to ensure compliance with data retention and disposal policies.
  • Employees are trained on data retention requirements and proper disposal methods.
  • Non-compliance with this policy may result in disciplinary actions and potential legal consequences.

Policy Review

This policy is reviewed annually or as necessary to accommodate changes in regulations, business requirements, or industry standards.