Data Retention Policy for ISO 27001: A Simple Guide (+ Template)

Most of the data companies store, they never use again. Industry research estimates that more than half of enterprise data is “dark,” collected and stored but never touched.

Every unused record must still be secured, backed up, reviewed, and handed over if a regulator or customer asks, so holding it is a cost and a liability rather than an asset.

An ISO 27001 data retention policy is how you stop the pile-up. It sets clear rules for what you keep, where, why, for how long, and how you delete it securely once it is no longer needed, tied back to your ISMS scope, your legal obligations, and the evidence an auditor expects to see.

Read on as we tell you everything you need to know about data retention…

What is a data retention policy under ISO 27001?

An ISO 27001 data retention policy is a formal document that defines what data your organization keeps, where, why, how long, and how you securely delete it once it is no longer needed.

Under ISO 27001:2022, it maps mainly to Annex A 5.33 (Protection of Records) and A.8.10 (Information Deletion), and helps you pass audits and meet privacy laws.

In practice, the policy governs the full lifecycle of your information: how each type of data is classified, how long it is kept and why, how it is protected while you hold it, and how it is securely disposed of at the end of its life.

Tying those rules back to your ISMS scope, legal and contractual obligations, and risk assessment turns a generic template into something an auditor will accept.

Three ISO 27001:2022 controls sit behind a retention policy:

• A.5.33: Protection of records requires you to keep a retention schedule and protect records while you hold them.
• A.8.10: Information deletion requires you to delete information when it is no longer needed.
• A.5.31: Legal, statutory, regulatory, and contractual requirements is where many of your retention periods actually come from. A good policy connects all three.

ISO 27001 data retention policy template

While every organization’s data retention policy will be unique to its specific circumstances, a template can give you a helpful starting point and ensure you cover all the necessary bases. Here is a downloadable template you can adapt to create your own ISO 27001 data retention policy.

ISO 27001 does not tell you how long to keep each type of record. Those periods come from tax and employment law, privacy regulations like GDPR, your contracts, and your own business needs, so every schedule looks a little different. The table below is a starting point to adapt to your own obligations, pairing common record types with example retention periods and the basis for each:

Record type	Example retention period	Basis
Financial and tax records	5 to 7 years (varies: e.g. US IRS up to 7, UK HMRC 6 plus current year)	Tax and accounting law
Employement and HR records	Duration of employment plus 3 to 7 years	Employment and labour law
Customer PII	Only as long as needed for the stated purpose, then delete or anonymise	GDPR / CCPA storage limitation
Contracts and agreements	Contract term plus 6 to 7 years after expiry	Statute of limitations, business need
Security and audit logs	90 days to 3 years (PCI DSS requires at least 1 year)	PCI DSS, incident response, risk assessment
System backups	Rolling window aligned to your RTO and RPO (e.g. 30 to 90 days)	Business continuity
Health records (if applicable)	6 years	HIPAA

ISO 27001 data retention policy requirements

ISO 27001 does not set fixed retention periods. Under Annex A 5.33 (Protection of Records) and A.8.10 (Information Deletion), you are required to define the records you hold, protect them while you keep them, retain each for a justified period tied to legal and business needs, keep them retrievable, and delete them securely once that period ends.

In practice, ISO 27001’s data retention requirements break down into the following:

• Evidence of deletion: Keep a disposal log that proves deletion actually happens.
• Retention schedule: Define each record type and how long you keep it, with a legal or business reason for the period.
• Protection of records: Guard records against loss, destruction, falsification, unauthorized access, and unauthorized release while you retain them.
• Retrievability: Keep records accessible and readable for the full retention period, even as systems and file formats change.
• Secure disposal: Delete or destroy records securely once their retention period ends (A.8.10), including copies in backups and archives.
• Legal and contractual basis: Tie retention periods to the obligations you identify under A.5.31.
• Ownership and review: Assign owners for records and review the schedule at least annually.

What goes into the ISO 27001 data retention policy: the core components

To create a robust and effective data retention policy that aligns with ISO 27001 policies, you need to include many foundational components. A common mistake is to overcomplicate the policy; the best ones are not the longest, but the clearest. 

At a minimum, your policy should be built around these core elements to ensure it is practical, auditable, and meets your organization’s needs.

Scope and data classification:

• The first step is to clearly define what information your policy covers. This includes identifying all the types of data your organization handles, such as customer data, employee records, financial information, and system logs.
• Once identified, you need to classify this data based on its sensitivity, criticality, and any legal or regulatory requirements that apply to it.

Retention periods and rationale:

• For each category of data you’ve identified, you must specify exactly how long it will be kept. These retention periods shouldn’t be arbitrary; they need to be based on a clear rationale that considers legal, regulatory, contractual, and business requirements. 
• For instance, tax laws might require you to keep financial records for a certain number of years, while GDPR requires that personal data is only kept for as long as necessary for the purpose it was collected.

Secure disposal procedures:

• Your policy must outline the secure methods you will use to dispose of data once its retention period has expired. This is a critical step in minimizing the risk of a data breach. 
• The disposal methods will vary depending on the nature of the data and could include physical destruction for paper records (like shredding) or cryptographic wiping for electronic data to ensure it cannot be recovered.

Roles and responsibilities:

• A policy is only effective if people know their role in implementing it. You need to clearly define who is responsible for managing the data retention lifecycle. 
• This includes identifying who has the authority to define retention periods, who is responsible for ensuring data is securely stored, and who is accountable for carrying out the disposal procedures.

“As the CEO, my bandwidth is limited. It is best spent building our product, instead of writing policies”

— Venkata Pingali, Co-founder and CEO, Scribble Data

How to write a data retention policy?

Creating a data retention policy document is a fantastic start, but the real test is in its implementation. A policy sitting on a server does nothing to protect your data. To bring it to life, you need a clear, methodical approach that embeds these principles into your daily operations. Modern ISO 27001 software platforms close this implementation gap by tracking the controls that depend on the policy, alerting owners when retention deadlines approach, and storing the evidence auditors will eventually request without requiring manual chase-down. 

Once you know what the policy must cover, writing it is a six-step process:

1. Inventory and classify your data

List the data your organization holds across systems, then group it by type and sensitivity, such as personal, financial, or operational. You cannot set retention rules for data you have not mapped.

2. Identify your retention obligations

Work out the legal, regulatory, and contractual rules that apply to each data type, drawing on the obligations you documented under A.5.31. This is where most of your retention periods come from.

3. Set a retention period and basis for each record type

Assign each type a period, record the reason behind it, and compile these into your retention schedule. Where the law is silent, base the period on business need and keep it as short as is practical.

4. Define storage, protection, and disposal

Decide how each record type is stored and protected while you retain it, and how it is securely deleted or destroyed at end of life, including copies held in backups and archives.

5. Assign owners and set your hold and exception processes

Name who owns each record type and the policy overall, and define how a legal hold pauses deletion and how exceptions are requested, approved, and logged.

6. Approve, publish, and review

Get leadership approval, communicate the policy to staff, and schedule a review at least once a year and after any significant change in systems or regulation.

ISO 27001 Data Retention Policy Best Practices

These best practices will make your policy not only compliant but also practical and sustainable in the long run.

1. Automate the policy wherever you can

Manually tracking the retention period for every single piece of data is a welcome sign for human error and inefficiency.  Use technology to automate the enforcement of your retention rules. Many modern systems for document management and cloud storage have features that can automatically flag, archive, or delete data based on the lifecycle rules you set. Automation reduces risk, saves time, and ensures your policy is applied consistently across the board.

2. Work collaboratively, not in a Silo

When creating and reviewing your policy, involve key stakeholders from different parts of your business, including IT, legal, and compliance teams. This collaboration is necessary. 

Your legal team can provide essential guidance on regulatory requirements, while your IT team can speak to the technical feasibility of implementing the policy. This cross-functional approach keeps your policy comprehensive, realistic, and has buy-in from the entire organization.

3. Document everything in a very detailed manner

Maintain clear and detailed records of all your data retention and disposal activities. This includes your retention schedule, the rationale behind your decisions, and logs of when data was securely destroyed. 

This documentation is your proof of compliance. In the event of an audit or a legal challenge, this paper trail will help you show that you have a systematic and defensible process in place.

Automate ISO 27001 data retention with Sprinto

Sprinto is an AI-powered autonomous trust platform that runs your ISO 27001 program continuously instead of once a year.

For data retention, it gives you a policy and schedule template already mapped to A.5.33 and A.8.10, so you start from a working draft rather than a blank page.

With 200+ integrations, it connects to your cloud, identity, and data systems and monitors the controls behind your policy: whether retention and deletion are actually happening, where data is over-retained, and whether the evidence is in place.

That evidence, including proof that deletion runs, is collected automatically, so the audit becomes a matter of showing what already exists rather than reconstructing it.