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Setting retention periods and recording deletions

How a company records how long each kind of data is kept and why, schedules and proves each deletion, and places a hold when a record must be kept.

Updated

Personal data may be kept only as long as you need it. The retention register records, for each kind of data, how long it is kept, what the period is counted from, what puts the period there, and whether anything actually deletes it. Asiri does not hold your records and does not delete anything in your systems. It keeps the schedule, the runs and the proof of each one.

Who can do this

An owner, editor or contributor of your workspace can add rules, set a period and name who carries out a deletion. Scheduling a deletion, recording it, recording an exception, and placing or lifting a hold need an owner or editor. A viewer can see the register.

Find the register

Open Records & controls → Retention & deletion. The tabs are Every rule, No end date, Needs a person, Required by law and Under a hold. From the top of the page you can open Deletion runs and Holds, or press Add a rule.

Because Asiri cannot count your records, it cannot say how many are past their date. It says instead which rules would delete nothing if their date arrived today.

Add a rule

Press Add a rule. There are two steps.

  1. Under Scope, say What kind of data and give the Activity reference it belongs to.
  2. Under Retention period, choose How long, then what it is Counted from, such as The account closing or The last contact. If none fits, choose Something else — an event we can name and describe it under What the period runs from.
  3. Say what puts the period there:
    • The company decided it. Write Why you chose it. Shorter is always easier to defend than longer.
    • A law requires it, or A regulator requires it. Give Which instrument, Which clause and Which records it applies to. Asiri does not supply the citation. If you do not know the clause, record the period as your own decision and add the clause later.
  4. Say whether anything deletes: Documentation — somebody deletes when the date comes, or An enforced deletion — it already runs without anybody remembering. Choose the second only if something in your own systems already deletes on this schedule. If it does, tick whether the deletion reaches the backups as well as the live systems.

Press Add the rule.

Keeping data until someone asks

If you choose until they ask us to stop, the rule has no end date. Nothing is counted from it and no deletion can ever fall due. The register lists it under No end date as a gap. To close the gap, decide the longest you would keep the data once there is no request to act on, for example 12 months after the last contact, and record that instead.

On the rule

The rule's page shows How long it is kept, What puts the period there, Whether anything deletes, Where deletion reaches and Who carries it out.

  • For a rule with no end date, press Set a period on the register. Choose How long it is kept and What decided it, fill in Which instrument, or why you chose it, and press Set the period.
  • For a rule a person carries out, press Name who carries it out, choose the person, and press Record the owner. A week before a scheduled run falls due, it goes on their work list.

To change what puts the period there, what it is counted from, or how deletion runs, press Record a replacement rule, then end this one with Take this record out of the register. Recording a replacement does not end the old rule.

Schedule and record a deletion

Open Deletion runs.

  1. Under Schedule a deletion, choose the Retention rule and the Scheduled date, press Schedule deletion, and then Confirm and schedule. This is the authority to delete the records the rule covers on that day. Nothing is deleted now.
  2. When the deletion has been carried out in your systems, record it on the run: the Records deleted, the Proof reference, and whether the Deletion reached backups. Press Record execution.
  3. If the deletion is not going ahead, open Not carrying it out, write Why this deletion is not being carried out, and press Record the exception.

A deletion is not complete because its date has passed. It is complete when the outcome and the proof are recorded.

Place a hold

A hold stops deletion for one named record, for example while a claim or an investigation is open. It does not change the retention rule.

  1. Open Holds.
  2. Under Place a hold, give the Record reference and Why deletion must stop, and press Place hold.

A scheduled run under a held record is paused until the hold is lifted. To lift it, write Why the hold can end and press Lift hold. The original hold stays in the history.

Common questions

"Is a period with no deletion a finished rule?" It is a written schedule. If nobody carries it out and nothing runs, nothing has been deleted.

"Does a period a law requires outrank an erasure request?" Where a law or regulator requires you to keep a record, you keep it. Name the instrument and the clause on the rule, so anyone can check.

"Does Asiri delete the data?" No. Deletion happens in your own systems. Asiri records the schedule and the proof of each run.

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