General Counsel

May 30, 2025

6 min. read

Make your own ISO 27001 data retention policy

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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.

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.

Data typeRetention periodRationaleDisposal method
Employee records7 yearsLocal labor laws and tax audit requirementsSecure shredding, deletion
Email communications3 yearsOperational need, potential legal holdAutomated purge
Access logs12 monthsSecurity incident investigation requirementSystem log rotation
Customer invoices10 yearsNational accounting standards (e.g. GAAP)Archival and secure deletion
Marketing data (PII)6 monthsGDPR compliance (consent expiration)Manual and system deletion
Data retention policy 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.

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.

Data typeLegal basisOperational needRecommended retention
Payroll recordsTax and employment lawHR dispute resolution7 years
Audit logsISO 27001 Annex A.12.4.1 requirementIncident response and investigations12 months
Client contractsStatute of limitations (civil law)Renewal and litigation readiness6 years
CCTV footageGDPR proportionality principleTheft investigation30 days
CRM dataConsent under GDPR / PECRLead nurturing and re-engagement6–12 months
Legal and operational justification mapping

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.

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.

System or platformRetention mechanismResponsible roleVerification process
Microsoft 365Retention policy via Compliance CenterIT Security AdministratorQuarterly audit review
SIEM system (e.g. Splunk)Log aging and scheduled deletionSOC AnalystMonthly integrity checks
HRIS softwareData lifecycle rulesHR ManagerAnnual compliance checklist
Cloud storage (e.g. AWS S3)Lifecycle policies and bucket taggingDevOps EngineerWeekly policy enforcement logs
Example of technical and procedural controls

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.

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.

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General Counsel

He is regulatory compliance strategist with over a decade of experience guiding fintech and financial services firms through complex EU legislation. He specializes in operational resilience, cybersecurity frameworks, and third-party risk management. Nojus writes about emerging compliance trends and helps companies turn regulatory challenges into strategic advantages.
  • DORA compliance
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