Data Retention & Disposal Policy (OP-POL-003)
1. Objective
This policy establishes comprehensive requirements for retaining and disposing of data in a manner that meets business, legal, and regulatory requirements while minimizing storage costs and privacy risks. The policy addresses unnecessary data retention in the video streaming platform environment while ensuring compliance with applicable regulations and maintaining operational efficiency across all data lifecycle stages.
2. Scope
This policy applies comprehensively to all data created, collected, processed, or stored by [Company Name] across all operational systems and environments. The scope encompasses user-generated content, user personal data, business records, system logs, and backup data across all data storage systems, applications, and geographic regions where [Company Name] operates its services.
3. Policy
3.1 Data Retention Framework
- Data retention must be based on business necessity, legal requirements, and privacy principles for all data types.
- Minimum necessary retention periods must be established based on business and legal requirements for each data category.
- Automated retention and disposal procedures must be implemented where technically feasible to ensure consistency.
- Regular review and updates must be conducted of retention schedules based on changing requirements.
- Documentation must be maintained of retention decisions and legal basis for retention periods.
- Integration must be ensured with data classification and handling procedures across all systems.
3.2 User Data Retention
User personal data retention must comply with privacy regulations and user expectations:
Account and Profile Data:
- Active user accounts: Retained while account remains active
- Inactive user accounts: Deleted after [Number, e.g., 3] years of inactivity unless legal basis for longer retention
- User profile information: Retained per user privacy settings and legal requirements
- Account deletion: Complete deletion within 30 days of user deletion request
Viewing History and Preferences:
- Individual viewing history: Retained for [Number, e.g., 2] years or per user preference settings
- Recommendation data: Retained for [Number, e.g., 1] year unless user opts for longer retention
- Search history: Retained for [Number, e.g., 6] months unless user deletes sooner
- User preferences and settings: Retained while account is active
User Communications:
- Support communications: Retained for [Number, e.g., 3] years for quality and training purposes
- User-to-user messages: Retained per platform terms, typically [Number, e.g., 1] year
- Content creator communications: Retained for [Number, e.g., 5] years for business relationship management
3.3 Content Retention
User-generated content and platform content require specific retention approaches:
User-Generated Content (UGC):
- Active content: Retained while account is active and content is published
- Deleted content: Removed from platform within 30 days, may be retained for [Number, e.g., 90] days for abuse detection
- Violating content: Retained for [Number, e.g., 1] year for appeal processes and pattern analysis
- Content from deleted accounts: Deleted within 30 days unless legal hold applies
Licensed and Premium Content:
- Licensed content: Retained per licensing agreements and content owner requirements
- Content metadata: Retained for 7 years for rights management and reporting
- Content analytics: Retained for [Number, e.g., 3] years for business intelligence and optimization
Content Moderation Data:
- Moderation decisions: Retained for [Number, e.g., 2] years for consistency and appeals
- Content review logs: Retained for [Number, e.g., 1] year for quality assurance and training
- Appeal records: Retained for [Number, e.g., 3] years for process improvement and compliance
3.4 Business and Operational Data
Business records must be retained according to legal and operational requirements:
Financial Records:
- Transaction records: 7 years for tax and audit purposes
- Revenue and billing data: 7 years for financial reporting and compliance
- Contract and agreement records: Duration of contract plus 7 years
Security and Audit Logs:
- Security incident logs: [Number, e.g., 3] years for forensic analysis and compliance
- Access logs: [Number, e.g., 1] year for security monitoring and investigations
- System audit logs: [Number, e.g., 2] years for compliance and operational analysis
- Vulnerability scan results: [Number, e.g., 2] years for trend analysis and compliance
Employee and HR Data:
- Employee records: 7 years after employment termination
- Training records: [Number, e.g., 3] years for compliance and certification tracking
- Background check records: Disposed immediately after hiring decision
3.5 Legal Holds and Litigation Support
Data subject to legal proceedings requires special handling:
- Suspension of normal retention schedules for data subject to legal holds
- Identification and preservation of relevant data for litigation support
- Coordination with legal counsel for hold notifications and scope determination
- Documentation of legal hold procedures and data preservation actions
- Release of legal holds only upon legal counsel authorization
3.6 Geographic and Regulatory Considerations
Data retention must comply with local laws and regulations:
- GDPR right to erasure compliance with 30-day deletion timelines
- CCPA consumer deletion rights with verification and authentication
- COPPA parental consent and data deletion for users under 13
- Regional data residency requirements affecting retention locations
- Cross-border data transfer restrictions for retained data
3.7 Data Disposal Procedures
Secure data disposal must ensure complete data destruction:
- Cryptographic erasure for encrypted data through secure key destruction
- Multi-pass overwriting for magnetic storage devices
- Physical destruction for end-of-life storage devices
- Certificate of destruction for highly sensitive data disposal
- Verification of complete data removal from all systems and backups
4. Standards Compliance
| Policy Section | Standard/Framework | Control Reference |
|---|---|---|
| 3.1 | ISO/IEC 27001:2022 | A.8.3.3 |
| 3.1 | PCI DSS v4.0 | Req. 3.2.1 |
| 3.2 | GDPR | Art. 17 |
| 3.2 | CCPA | § 1798.105 |
| 3.2 | COPPA | § 312.10 |
| 3.2 | PCI DSS v4.0 | Req. 3.2.1 |
| 3.4 | SOC 2 Type II | CC6.5 |
| 3.4 | PCI DSS v4.0 | Req. 9.8.1 |
| 3.7 | NIST SP 800-88 | Media Sanitization |
| 3.7 | PCI DSS v4.0 | Req. 9.8 |
5. Definitions
Data Retention: The practice of storing data for a defined period based on business, legal, or regulatory requirements.
Right to Erasure: GDPR provision allowing individuals to request deletion of their personal data under specific circumstances.
Legal Hold: A process that suspends normal retention schedules to preserve data relevant to litigation or investigations.
Cryptographic Erasure: A data destruction method that renders encrypted data unrecoverable by securely destroying encryption keys.
Data Minimization: The principle of collecting and retaining only the minimum amount of personal data necessary for specified purposes.
Data Subject Rights: Individual rights under privacy laws including access, rectification, erasure, and portability of personal data.
Retention Schedule: A systematic plan that defines how long different types of data should be retained before disposal.
6. Responsibilities
| Role | Responsibility |
|---|---|
| Data Protection Officer | Develop retention schedules, ensure privacy law compliance, and coordinate data subject rights fulfillment including deletion requests. |
| [Legal Department/Team Name] | Define legal retention requirements, manage legal holds, and provide guidance on regulatory compliance and litigation support. |
| [IT/Infrastructure Department/Team Name] | Implement automated retention and disposal procedures, execute secure data destruction, and maintain disposal documentation. |
| Business Data Owners | Define business retention requirements, approve retention schedules, and ensure operational compliance with retention policies. |
| [Security Department/Team Name] | Monitor data disposal procedures, investigate retention violations, and ensure secure destruction of sensitive data. |
| Compliance Team | Audit retention practices, monitor regulatory compliance, and report on data retention metrics and violations. |