Make your own ISO 27001 data retention policy

Data piles up fast—faster than most organizations are prepared for. From employee records and client emails to access logs and invoices, the sheer volume of data we collect can quickly spiral out of control. That’s why ISO 27001 doesn’t just suggest having a data retention policy—it expects it. But here’s the catch: the standard doesn’t tell you exactly what your policy should say. It simply mandates that you define, document, and enforce retention in a way that reflects your legal, business, and security needs.

This creates a unique challenge. You’re not just following a template—you’re building a policy tailored to your organization’s risk profile and regulatory context. Without further ado, let’s break down what it takes to make your own ISO 27001-compliant data retention policy—one that’s practical, auditable, and aligned with real-world requirements.

Why data retention matters in ISO 27001

At its core, ISO 27001 is about managing information security risks. And in the context of data retention, the longer you keep data, the greater your risk exposure becomes. Whether it’s personally identifiable information (PII), financial records, or system logs, excessive retention often becomes a liability rather than an asset.

Regulators have taken notice. Under the General Data Protection Regulation (GDPR), for instance, data must be “kept in a form which permits identification of data subjects for no longer than is necessary” (Article 5(1)(e)). Likewise, industry standards like PCI DSS and legal frameworks such as the ePrivacy Directive push organizations to limit data storage.

Yet, ISO 27001 doesn’t tell you what to retain or how long to keep it. Instead, it expects organizations to define retention within their own Information Security Management System (ISMS). That makes the policy not just a checkbox, but a business-critical decision tool.

This sets the stage for what comes next—understanding the pillars that make a data retention policy work under ISO 27001.

PRO TIP

Conduct an annual Retention Risk Review: each year, rank your data categories by residual risk (sensitivity × retention duration) and adjust retention periods for the highest-risk items first—this keeps your policy aligned with evolving threats and regulations.

Key components of a data retention policy

A common mistake I see when reviewing data retention policies is overcomplication. The best policies aren’t the longest—they’re the clearest. To build your own, you need to define specific components that serve as your foundation. These typically fall into four core categories: data type, retention period, rationale, and disposal method.

Let’s break these down into a reference structure.

By documenting this structure, you create transparency for auditors, clarity for staff, and defensibility if regulators come calling.

But structuring is only half the battle. The next challenge is aligning your retention periods with legal and operational requirements—without locking yourself into a rigid system.

PRO TIP

Use a Centralized Retention Matrix spreadsheet that automatically highlights when each data category hits 75% of its retention lifecycle—set calendar reminders to trigger disposal workflows before data becomes stale or noncompliant.

Balancing legal, operational, and security needs

The ISO 27001 standard leaves room for flexibility, but laws and industry regulations do not. The real difficulty is resolving the tension between keeping data long enough to support operations and not so long that it creates regulatory or security exposure.

In my experience, organizations tend to err on the side of caution and retain too much. This increases not only storage costs but also risk. A smarter approach is to use risk assessments to inform your retention timelines.

One useful method is aligning each category of data with its specific legal basis and operational justification. The table below illustrates this concept more concretely.

Authoritative resources like the UK’s ICO retention guidelines and CNIL recommendations can help validate your retention periods when tailoring your policy for different jurisdictions.

With this foundation, you’ll be ready to formalize your policy—but only if you can make it work operationally.

PRO TIP

Build a Legal-Ops Concurrence Log: for each retention period you choose, record the exact legal citation (e.g., GDPR Art. 5(1)(e) or SOX § 404) and an operational note (e.g., “supports month-end closing”). That one-page log simplifies auditor Q&A and executive sign-off.

From policy to practice: implementing retention controls

It’s one thing to write a retention policy. It’s another to enforce it. Many organizations stumble here, often due to poor tooling or lack of ownership. Your ISMS needs technical and procedural controls to ensure expired data is actually disposed of securely.

Retention enforcement often requires configuring systems like email servers, CRM tools, log management platforms, and cloud storage with specific lifecycle rules. Without automation, enforcement becomes a manual—and error-prone—task.

To stay compliant with ISO 27001 Annex A.8.3.3 (Disposal of media) and A.18.1.3 (Protection of records), you need to prove that data disposal is both systematic and irreversible.

The transition from a written policy to a working system depends on clear accountability and tooling. And once implemented, this framework becomes a powerful part of your ISO 27001 controls landscape.

PRO TIP

Leverage Automated Lifecycle Rules in your primary platforms (e.g., M365, AWS S3) by defining tags like retention_expires=YYYY-MM-DD; couple this with a weekly script that quarantines soon-to-expire data for IT review, ensuring nothing slips through manual gaps.

CyberUpgrade makes ISO 27001 data retention easy to enforce—and even easier to prove

One of the most overlooked yet heavily audited ISO 27001 areas is data retention. CyberUpgrade helps you close that gap with a prebuilt Data Retention Matrix tailored to your regulatory environment. Instead of wrestling with spreadsheets or vague policies, you get a dynamic, ISO-aligned framework where every data category is mapped to retention timelines, disposal methods, and legal justifications.

Our platform integrates with your systems—from Microsoft 365 to AWS S3—automating lifecycle rules and tracking execution. That means expired data is purged or archived without human error, and your documentation stays audit-ready with version control, logs, and role-based responsibilities already captured.

Whether you’re drafting your first policy or tuning a legacy one, CyberUpgrade gives you the tools, templates, and automation to make your retention policy real. Say goodbye to data bloat, regulatory ambiguity, and last-minute audit scrambles—and hello to an enforceable, justifiable, and defensible data lifecycle. Ready to tighten your ISMS without adding headcount? Let’s talk.

Are you ready to defend your data lifecycle?

Writing a data retention policy for ISO 27001 isn’t just about avoiding audit findings or ticking a compliance box. It’s a way to reduce risk, clarify responsibility, and strengthen your organization’s digital hygiene. But it only works if you treat it as a living document—something reviewed annually, mapped to changing laws, and embedded in your technical systems.

So if your current policy is collecting digital dust, it might be time to revisit it with fresh eyes and updated tools. Ask yourself: If an auditor walked in tomorrow, could you show not only what your retention periods are—but why they exist and how they’re enforced?

Get that right, and your data retention policy won’t just be compliant—it’ll be defensible.