A retention policy is one of the few legal documents users actually read, usually at the moment they are deciding whether to trust you. Writing it clearly is both a compliance task and a conversion one.
Retention is a decision, not a default
Most systems keep data indefinitely because nobody chose otherwise. Storage is cheap and deletion requires deliberate work, so the path of least resistance is accumulation.
That default is a liability. Data held past its usefulness still appears in breaches, still must be produced for access requests, and still counts against data minimisation obligations. Every dataset should have an expiry chosen on purpose.
Set a period per data type
A single site-wide retention figure is almost always wrong, because different data has genuinely different useful lives.
- Aggregate analytics: long retention is fine, since it contains no personal data.
- Raw event logs: short, typically days to weeks — this is where risk concentrates.
- Account records: retained for the life of the account plus a defined wind-down.
- Billing records: dictated by tax law, often several years, and not yours to shorten.
- Support conversations: bounded, and separated from the account record.
Write it so a non-lawyer can act on it
State what you keep, for how long, why, and what happens at the end. Users are trying to answer three questions: what do you have, how long do you have it, and how do I make it stop.
Avoid 'as long as necessary'. It is technically defensible and reads as evasion, which is the opposite of what the document is for.
Automate deletion or it will not happen
A policy nobody enforces is worse than none, because it is a documented commitment you are visibly failing. Manual quarterly cleanups are skipped the first busy quarter.
Implement expiry at the storage layer where possible, and log deletion runs so you can evidence compliance rather than assert it. Remember backups: data deleted from production but retained in backups is still retained, and your policy should say how that is handled.
Key takeaways
- Indefinite retention is a default, not a decision — and it is a liability.
- Set separate periods per data type; one global number is wrong.
- Replace 'as long as necessary' with actual durations.
- Automate deletion and account explicitly for backups.
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