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 | 5ā7 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 | 1ā3 years | Depending on regulatory and security requirements |
| Support & Communication Logs | 1ā2 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.