Data Retention Periods: How Long Should Each Type of Data Be Kept?

Keeping personal data indefinitely means that responsibility continues even when the data is no longer needed. The right approach is to determine the processing purpose, mandatory retention grounds, and destruction date separately for each data type.

How Is the Retention Period for Personal Data Determined?

A retention period is not an arbitrary number chosen on the day data enters a system. First, assess the purpose for which the data is processed, when that purpose ends, and whether there is another legal, contractual, or operational reason to retain the data.

“Maybe we’ll need it someday” is not sufficient justification on its own. Once the purpose ends, the data should be deleted, destroyed, or anonymized so that the individual is no longer identifiable. For example, contact details collected through an application form cannot automatically be retained for marketing after the application process ends; marketing requires a separate and valid legal basis for processing.

The following sequence can help guide the decision:

• Document why the data was collected.
• Determine when that purpose ends.
• Check whether a longer retention period is required by law, contract, or the risk of a dispute.
• Define the destruction method to be applied when the period expires.
• Record the decision in the data inventory and the retention and destruction policy.

How Should Retention Decisions Be Made by Data Type?

A single “organization-wide retention period” is generally not sufficient. Customer records, employee files, camera footage, call recordings, and marketing consents serve different purposes; therefore, their start and end conditions may also differ.

For example, if the purpose of camera recordings is to support workplace security, footage should be retained only for as long as necessary for that purpose. If an investigation into an incident is ongoing, the relevant recording may be placed under a separate preservation process until the investigation is complete. However, retaining the entire camera archive indefinitely cannot be justified on the same grounds.

Similarly, a résumé submitted for a job application does not have the same lifecycle as an active employee file. If an application does not result in employment, the deletion timeline will be different from the retention approach applied while the employment relationship continues. This distinction means that the data inventory must show not only file names but also the underlying business processes.

How Should a Retention and Destruction Policy Be Established?

A Personal Data Retention and Destruction Policy is a working document that explains what data the organization retains, for what reason, for how long, and what happens when the retention period expires. The policy should not remain a purely legal document; it should be converted into rules that the IT, human resources, finance, security, and marketing teams can apply in practice.

For each record category, at least the following fields can be defined: data type, processing purpose, relevant system, starting point for the retention period, condition that ends the period, responsible team, and destruction method. For example, for “customer support records,” the starting point could be the closure of the request, the responsible team could be customer service, and the destruction method could be deletion from the live system while tracking the lifecycle of the data in backups.

The retention periods set out in the policy must also be reflected in the systems used by the organization. Check whether a record deleted from one application continues to exist in reporting systems, email archives, or backups. To compare current texts relating to legislation and organizational practices, organizations can consult a resource such as the KVKK and Data Privacy Resource Center.

How Should Periodic Destruction and Destruction Requests Be Managed?

Organizations should not assume that data will disappear automatically when its retention period expires. Deletion, destruction, or anonymization should be carried out according to a scheduled, documented, and auditable process. For data controllers with a retention and destruction policy, the interval for periodic destruction may be no longer than six months; where no policy exists, a shorter destruction schedule may be required.

When a data subject requests the deletion or destruction of their personal data, the request should be assessed separately. The request initiates a review of why the data is being retained and whether an ongoing retention obligation exists. Where appropriate, the request should be concluded within thirty days, and the action taken should be documented.

For example, when a customer account is closed, the account’s primary record may be deleted; however, documents directly related to an ongoing dispute may be retained in a separate, restricted-access area. This exception must not become a justification for keeping the customer’s entire history indefinitely.

Common Mistakes in Data Retention Processes

The most common mistake is applying the same retention period to every data type. The second is making deletion decisions based only on the primary application; mailboxes, external service providers, exported spreadsheets, and backups must also be included in the process.

Another issue is failing to specify when the retention period begins. If the statement “retained for two years” does not clarify whether the period is calculated from the date the record was created, the date the contract ended, or the date the account was closed, teams may apply different practices. For example, when monthly report summaries are prepared, the end of the underlying business relationship may be used as the starting point instead of the report creation date; this decision should be justified for the specific process.

As a final check, ask the following questions for each data category: Is the purpose still ongoing? Is there a legal or contractual reason to retain the data? Is access still necessary? Which systems will the data be destroyed in when the period expires, and how will the action be evidenced? The safest approach is to begin with a small pilot that tests the inventory, retention periods, and destruction workflow on a limited data set.

Frequently Asked Questions

Is there one retention period that applies to all personal data?

No. The period is determined based on the type of data, the processing purpose, and any ongoing legal or contractual requirements. Different rules may be needed for customer, employee, and camera records within the same organization.

How should data be destroyed when its retention period expires?

Depending on the structure of the system, data may be deleted, physically or digitally destroyed, or anonymized. The date, data group, and person responsible for the action should be documented.

Are personal data stored in backups also included in the retention period?

Backups should also be treated as part of the data lifecycle. The length of time data deleted from the primary system remains in backups and how it will be handled if restored should be defined separately.