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policies/Security/data_retention_disposal_guidance.md
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Data Retention & Disposal Guidance

Document owner: [Owner/Role]
Approved by: [Steering Committee / CISO]
Effective date: [YYYY-MM-DD]
Review cadence: [Annually]


1. Purpose & Scope

Implementation guidance for the Data Retention & Disposal Policy. Applies to IT, data owners, and Legal.


2. Automating Retention

  • Use lifecycle policies native to the storage platform (M365 retention labels, S3 lifecycle rules, database TTL/partition-drop jobs) rather than relying on manual deletion — manual processes are the reason retention schedules drift into indefinite retention.
  • Tag data at creation with its retention class so lifecycle rules can act on it automatically.

3. Sanitization Method by Media

Media Method
Cloud storage object Cryptographic erasure (delete the key) or platform secure-delete API
Local SSD/HDD (AMBER+ data) Cryptographic erasure preferred; full-disk overwrite if unencrypted
Physical media (RED data) Physical destruction (shred/degauss), logged
Backup tapes/snapshots Expire per retention schedule; confirm deletion propagates, don't assume

4. Right-to-Erasure Workflow

  1. Verify requester identity.
  2. Check for legal hold — if present, inform requester of the exception per §2.5 of the policy.
  3. Delete from primary systems, then trigger backup propagation (or document why not, e.g., immutable backup within its retention window).
  4. Confirm and log completion within the statutory window.

5. Checklist

Retention schedule (policy §2.1) mapped to actual system lifecycle rules, not just written down.
Legal hold process tested at least once with a mock hold.
Backup deletion propagation verified, not assumed.
Disposal of AMBER+STRICT/RED data logged with method and authorizer.


6. References