Information Governance

    What Is a Data Retention Policy and How Do You Implement One?

    In this article, we explore how a modern data retention strategy should be designed and implemented in 2025. We’ll look ...


    In this article, we explore how a modern data retention strategy should be designed and implemented in 2025. We’ll look at policies, governance, and the real-world challenges that organizations now face in a landscape shaped by evolving privacy laws, hybrid work, and AI-driven data growth. You’ll also see how well-defined strategies help enterprises reduce risk, increase efficiency, support compliance, and optimize costs. 

    What is Data Retention? 

    Data Retention is no longer just about storing information for a set period of time; it’s about balancing compliance, privacy, operational efficiency, and innovation. Every organization generates and consumes massive amounts of data across cloud platforms, SaaS applications, and hybrid infrastructures. Retention ensures that this data is kept only as long as it provides legal, regulatory, or business value. 

    Without a clear strategy, organizations risk over-retention, which drives up storage costs, increases exposure in the event of breaches, and complicates compliance with privacy laws. Under-retention, on the other hand, can result in fines, loss of evidence in legal disputes, or reputational damage. 

    Modern strategies are built on formal data retention policies that codify requirements across the enterprise. These policies define which data must be preserved, where it should reside, how it can be archived securely, and when it must be deleted. They are no longer static documents but living frameworks that adapt to evolving regulations, business needs, and technology shifts. 

    When data retention is treated as an integral part of a broader governance and privacy framework, organizations can build a sustainable approach that not only reduces risk but also strengthens compliance, improves adaptability, and enables long-term operational resilience. 

    What drives a Data Retention Strategy? 

    A modern data retention strategy is shaped by three primary forces: 

    • Business Data Creation and Usage Patterns
    • Regulatory and Industry Oversight
    • Privacy, Security, and Customer Rights 

    Business needs determine how long information remains valuable. For example, engineering data for infrastructure projects may require decades of retention, while transactional data in retail or hospitality may only be relevant for months. As organizations digitize operations, retention schedules increasingly need to align with both operational lifecycles and cloud platform capabilities. 

    Regulatory oversight continues to be a major driver, with industries such as energy, finance, and healthcare requiring extensive records to support audits, investigations, and consumer protection. Retention strategies must accommodate sector-specific requirements while avoiding over-retention that can inflate costs and risks. 

    Privacy and protection requirements have dramatically reshaped retention practices. Frameworks like GDPR, CCPA, and other global privacy laws establish that much of the data held by organizations belongs to individuals, not the company. This creates direct obligations for organizations to handle deletion requests, honor the right-to-be-forgotten, and apply retention limits to sensitive data. 

    The challenge today is balancing these forces. Organizations must design retention strategies that are flexible, adaptive, and technology-enabled, ensuring that data is preserved long enough to meet business and legal needs but also deleted or anonymized in alignment with privacy expectations. The result is a governance model that both reduces risk and supports trust with regulators, customers, and partners. 

    The High-Level View: Systems and Channels 

    An effective retention strategy begins with a clear understanding of the systems and channels where information is created, exchanged, and stored. Organizations today rely on a mix of cloud platforms, collaboration tools, and industry-specific applications, which makes it critical to know exactly where business records reside and how they move across the enterprise. 

    The mapping process should account not only for core business systems but also for the communication and collaboration tools that employees rely on in their daily work. This includes enterprise messaging, conferencing, file sharing, and even sanctioned use of social or mobile messaging platforms. Beyond digital platforms, paper-based records and voice interactions tied to business transactions also need to be factored into retention plans. 

    Representative categories include: 

    • Team Collaboration: Microsoft Teams, Slack, Google Chat 
    • Enterprise Social: Yammer (Viva Engage), Workplace by Meta 
    • Web & Video Conferencing: Zoom, Microsoft Teams, Google Meet 
    • Cloud-PBX / VoIP: RingCentral, Zoom Phone, 8x8 
    • Social Media: Facebook, X (Twitter), LinkedIn, Instagram, YouTube 
    • Messaging: WhatsApp, WeChat, Signal, Telegram 
    • Financial Platforms: Bloomberg, Refinitiv Eikon, Symphony 
    • File & Document Collaboration: Google Drive, Microsoft SharePoint, Dropbox, Box 

    Because the number of tools is vast, organizations must distinguish between officially approved channels, tolerated shadow IT, and prohibited platforms. A robust strategy will either restrict the use of unapproved channels or implement compliant retention processes around them. High-profile enforcement actions in financial services have shown how costly it can be to ignore unsanctioned communication platforms. 

    To keep retention strategies sustainable, many organizations define rules at the category level (e.g., email, chat, conferencing) and apply product-specific policies underneath. This approach minimizes frequent changes while ensuring governance adapts to evolving technology choices. 

    The Inclusion of Data Privacy in Your Data Retention Strategy 

    Data privacy has become inseparable from data retention. Modern strategies must account for where personal data lives, how long it is kept, and how deletion or anonymization is managed across systems. Privacy requirements are no longer limited to select geographies; they now span across global frameworks such as GDPR, CCPA, and many emerging regional laws. 

    Some business systems may not store sensitive personal data, but many do. HR applications, recruitment platforms, CRM systems, and even corporate email often contain detailed personal and protected information. For example, candidate applications and CVs may need to be deleted within months if the individual is not hired, while customer consent records or employee files may carry entirely different obligations. 

    To meet these requirements, organizations need a Privacy Data Map that aligns with their retention map. This map identifies systems and processes that handle personal data, links them to relevant retention rules, and clarifies how requests such as erasure or access will be fulfilled. GDPR’s Article 30 record of processing activities (ROPA) remains a cornerstone, requiring organizations to document processing purposes, legal bases, consent status, cross-border transfers, DPIA results, and more. 

    In practice, this means retention and privacy policies cannot be developed in isolation. Instead, retention strategies must incorporate privacy requirements, resolve contradictions, and ensure that governance frameworks allow for both regulatory compliance and operational efficiency. Integrating privacy into retention not only reduces compliance risk but also strengthens trust with employees, customers, and regulators.  

    Why You Need a Data Retention Policy 

    A data retention policy is like a playbook that helps everyone in a company understand what to do with information. It explains which data is important to keep, where it should live, and for how long. 

    Think of it this way: some information, like contracts, invoices, or employee files, needs to be kept for years because of business or legal rules. Other information, like draft notes or casual chats, may only need to stick around for a short time. A good policy gives clear guidance so people don’t have to guess. 

    It also answers practical questions: How should we save this record? When can we safely delete it? Do we move it to cheaper storage if we don’t use it every day? 

    These rules aren’t just about being organized; they’re often required by law, whether it’s privacy regulations like GDPR or industry-specific standards. Following the policy helps keep the company compliant, reduces clutter, and lowers risk for everyone who works there. 

    Why Not Keep Everything Forever? 

    It can be tempting to think the safest option is to keep every piece of data forever. In reality, that approach creates more problems than it solves. Storage costs continue to rise, and the more data you hold, the bigger the target you become for security breaches. Beyond that, privacy laws and industry regulations often require companies to delete certain types of data after a set period. 

    Electronic communications highlight this challenge. Unlike paper files, emails, chats, and digital messages come in massive volumes. Much of it is noise, like newsletters, notifications, and routine updates, but mixed in are business records that truly matter. Sorting one from the other isn’t always straightforward. 

    In the past, companies sometimes set blanket rules like “keep all emails for ten years.” But without automated expiration and deletion, those archives kept growing indefinitely. Today, organizations face additional complications such as legal holds, conflicting requirements across regions, or the need to preserve contracts and intellectual property for extended periods. 

    At the same time, financial and privacy pressures make it impossible or undesirable to retain everything. Sensitive data, such as personnel files, financial details, or health records, often have to be deleted much sooner. A balanced strategy recognizes these differences, keeping data only for as long as it serves a clear legal, regulatory, or business purpose, and then removing it securely once that purpose ends. 

    Covering The Basics with an Industry-Specific Template 

    Due to the complex nature of the regulatory frameworks, organizations often use an industry-specific data retention best practices template that includes several different retention puzzle pieces: 

    • Sarbanes-Oxley Act (SOX): Publicly traded companies in the US must comply with SOX, which requires the retention of financial documents, audit work papers, and other records for several years to ensure accountability and transparency. This helps prevent fraud and ensures that organizations can demonstrate compliance during audits. 
    • Payment Card Industry Data Security Standard (PCI DSS): Any organization that processes, stores, or transmits credit card data must comply with PCI DSS. Retention rules here focus on protecting sensitive cardholder data, limiting storage of payment information, and ensuring secure deletion once data is no longer needed. The goal is to reduce the risk of breaches and fraud. 
    • Health Insurance Portability and Accountability Act (HIPAA): In healthcare, HIPAA sets strict guidelines for how long patient health records must be maintained and how they should be secured. Policies ensure confidentiality, availability, and integrity of electronic health information, with severe penalties for non-compliance. 
    • General Data Protection Regulation (GDPR): Businesses that process or store personal information about EU citizens, even if they are outside the EU, must comply with GDPR. This regulation emphasizes minimizing data collection, limiting retention periods, and giving individuals rights over their personal information, such as the right to erasure. 

    Using a simple template is just a starting point, which should be refined to your organization’s specific needs, industry standards, and regulatory environment. 

    Why a Template is Only The Starting Point 

    Many organizations assume that adopting what peers are doing will cover their data retention needs. In reality, every company’s environment, regulatory exposure, and business processes are different. Templates can provide a useful baseline, but they rarely capture the nuances of multiple jurisdictions, the variety of systems in use, or the unique privacy obligations tied to specific industries. That’s why developing a full data retention strategy is such a tailored effort; it must be adapted to the organization’s structure, technology landscape, and long-term goals. 

    The Regulatory Landscape Is Constantly Evolving

    In all parts of the world, regulations are constantly shifting, especially as the influence of laws such as Europe’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) grows. New frameworks also keep coming into force; for example, the EU’s Digital Services Act (DSA) and Digital Markets Act (DMA) began enforcement recently, while several US states, such as Virginia, Colorado, and Connecticut, have rolled out new consumer privacy laws this year. These developments make compliance a moving target, requiring organizations to continually reassess their retention and privacy practices. 

    Data Keeps Growing, and the Number of Sources Continues To Expand

    The challenge today is not just the volume of data but the pace at which new tools and platforms are introduced. At the same time, many organizations still maintain a patchwork of legacy systems. Migrating from on-premises email servers or outdated archives can be expensive and complex, while leaving critical data in systems that are unsupported or unsearchable creates both compliance and security risks. 

    Cloud services have added another layer of complexity. While they offer scale and flexibility, not all providers give customers full control over retention or deletion. Some even charge significant fees for extracting large volumes of data, creating barriers to maintaining sovereignty over business records. 

    Beyond the official systems, there are also hidden risks. Departments may adopt external apps without fully considering retention or privacy obligations. For example, uploading production data into an AI tool for testing could inadvertently expose sensitive information without IT or compliance teams knowing. 

    This is why organizations must take full responsibility for every system their employees use. A strong retention strategy requires visibility into all data sources, active oversight of approved tools, and clear policies that prevent shadow IT from undermining compliance and security efforts. 

    Implementing a Data Retention Strategy – Best Practices 

    These five steps will aid in this process and help you operationalize a data retention strategy across your organization. 

    1. Monitor and Adapt to Changing Data Regulations

    Set up a process to continually track new and evolving laws that affect how long you must keep data and how it should be handled. This regulatory intelligence should be coordinated centrally, but must take into account every country, state, and business unit where your organization operates. 

    In addition to knowing the rules, you also need to understand the different categories of records your organization creates, such as financial records, employee files, customer data, or product documentation. Each category can carry different retention requirements. 

    To make this manageable, develop a company-wide taxonomy, a consistent way to name and classify these record types. This not only helps people find the information they need but also ensures the organization can apply the correct retention and deletion rules in a reliable and repeatable way.

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    2. Build a Data Map of Business and Geographic Requirements

    Different regions and industries often have unique retention and privacy rules. To manage these effectively, organizations should create a detailed map that shows where data is generated, where it is stored, and which regulations apply. This makes it easier to see conflicting obligations and design policies that address them consistently. 

    For example, Europe consolidated many rules under GDPR, but certain national requirements still apply, such as specific banking laws in Luxembourg or stricter data handling rules in Switzerland. Similarly, data stored in the UK may follow different rules if regulations diverge further from EU standards. In the US, states like California, Virginia, and Colorado have introduced their own privacy frameworks, each with different retention expectations. 

    By visualizing these variations, companies can spot risks early and avoid one-size-fits-all policies. A strong data map connects business units and geographies to the relevant laws, helping teams understand where records and personal data live and what retention obligations apply. This ensures compliance while keeping the strategy practical and transparent for employees across the organization. 

    3. Maintain the Data’s Regulatory and Organizational Information

    Today, data is often traveling through various internal and external systems. While your data might have been collected in Germany or France, the Account Manager fulfilling the order might be based in the UK, using a CRM system where the data storage is in the US. 

    To decide where data retention obligations will be applicable, where the data is and should be stored, and what data might need to be moved or excluded from certain processes, it is mandatory to not only understand the source of the data but to make its origin identifiable throughout its lifecycle. 

    Therefore, implementing a data source catalog and a metadata schema that keeps this information intact is crucial to maintaining and sustaining the strategy over time as data retention regulations and obligations change.  

    4. Identify and Manage the Various Regulatory Subjects

    Every organization has multiple groups of people impacted by retention requirements: employees, executives, customers, patients, partners, advisors, and even regulators themselves. The specifics depend heavily on the industry. 

    It’s important to match each group to the rules that apply. For example, the CFO of a public company must comply with Sarbanes-Oxley (SOX) retention and audit obligations, while end users of a digital platform are protected by privacy laws like GDPR when their personal data is stored. 

    To manage this effectively, organizations should create a clear map of stakeholder groups, identify the regulations that apply to each, and define responsibilities. Supporting this with training, awareness campaigns, and clear communication ensures that each audience understands what is required. This proactive approach helps embed compliance into day-to-day operations and makes your data retention strategy more practical and sustainable. 

    5. Communicate Regularly, and Communicate Openly

    The only way to ensure your data retention strategy works is by communicating the relevant retention obligations to the employees. An excellent way to make this work is by regularly meeting with IT management and their counterparts in Data Protection/Privacy. Knowing which projects are about to be kicked off, which systems are being introduced, and where existing tools are getting replaced means you can get involved in the process at the right time and put data retention requirements into the project plan or vendor selection process. 

    Another vital step is to educate employees on the processes and technologies used to identify records and personal data in existing data stores, applications, and business tools. The more people understand what needs to be kept, what for, and how long, they can already put appropriate measures and customized policies into the applications they use. A good example is moving to Exchange Online, where administrators can create a comprehensive retention framework for email, which can then be applied to all mailboxes or specifically adjusted for certain departments. 

    communicate

    How CaseFusion Enhances Your Data Retention Policy 

    Technology plays a key role in making retention policies practical, and this is where Cloudficient’s CaseFusion can make a significant difference. CaseFusion helps organizations simplify and strengthen their data retention strategy by: 

    • Streamlining Legal and Compliance Workflows: CaseFusion automates the collection, classification, and preservation of data, ensuring that retention rules and legal hold requirements are met without manual overhead. 
    • Improving Visibility and Control: With centralized oversight, organizations can see exactly where data resides, how it is being managed, and when it is due for deletion, reducing both compliance risk and operational inefficiency. 
    • Supporting Privacy Obligations: CaseFusion makes it easier to respond to data subject requests and enforce right-to-be-forgotten requirements by quickly identifying and managing personal data across multiple systems. 
    • Reducing Cost and Complexity: By consolidating processes that are often spread across multiple tools, CaseFusion lowers operational costs while increasing reliability. 

    By integrating CaseFusion into a data retention program, companies gain a practical way to enforce policies, support legal and privacy teams, and maintain trust with regulators and customers alike. 

    Closing Thoughts 

    A good Data Retention Strategy should keep track of the data and how the organization uses it. But it can also inform how the company “should” use the data. And in that context, it might be feasible to discuss which systems are really required and which ones are only remaining for historical reasons. Is anyone still using the chat feature of the intranet, given that Teams is integrated into many other workflows? If nobody uses the intranet chat, why not switch it off and move the chat data to a searchable archive? 

    At Cloudficient, we work with organizations that need to modernize how they manage compliance, discovery, and retention. For legal teams, the challenge isn’t just about retiring outdated systems. It is about ensuring that critical evidence, records, and sensitive data are preserved, discoverable, and defensible in court or regulatory investigations. 

    Our unmatched next-generation technology enables legal and compliance teams to gain control over data across cloud and legacy systems, enforce consistent policies, and respond to legal or privacy requests with confidence. Cloudficient remains focused on client needs, delivering SaaS solutions that are reliable, scalable, and built to handle the realities of today’s compliance and legal landscape. 

    If you’d like to learn how CaseFusion and Expireon can enhance your legal and compliance strategy, visit our website or contact us today. 

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