Data Retention Requirements: ISO 27001 and SOC 2 Frameworks

Effective data retention is critical for maintaining compliance and ensuring information security. Two widely recognized frameworks, ISO/IEC 27001 and SOC 2 (particularly the Trust Services Criteria), provide clear guidelines for managing data retention.

This information should be taken in concert with regional jurisdictions and regulations on Data Privacy and Information Security Laws by Country-Governance Library.

ISO 27001:2022 Data Retention Requirements:

The 2022 update to the ISO 27001 standard emphasizes robust information lifecycle management, explicitly including data retention and disposal now also across unstructured data. Organizations must:

Clearly define retention periods for information assets based on legal, regulatory, contractual, and operational requirements.
Regularly review and update retention periods, ensuring compliance with evolving laws and organizational policies.
Implement mechanisms to securely dispose of information when it reaches the end of its retention period, preventing unauthorized recovery or access.
Maintain records documenting compliance with retention policies and demonstrating evidence of secure data disposal.

Key ISO 27001 Controls Relevant to Retention:

Control 5.32 (Information Deletion): Requires secure deletion or destruction of information no longer required.
Control 8.2 (Information Classification): Mandates classification of information according to sensitivity and retention requirements.
Control 5.15 (Compliance with Legal and Contractual Requirements): Ensures that retention policies reflect legal and contractual obligations.

SOC 2 Trust Service Criteria Data Retention Requirements

SOC 2, governed by the Trust Service Criteria (TSC), emphasizes data retention as a critical component of information security, availability, processing integrity, confidentiality, and privacy.

Organizations adhering to SOC 2 must:

Establish formal data retention policies aligned with business objectives, regulatory requirements, and contractual commitments.
Define and implement processes for data disposal, ensuring that expired data is securely and irreversibly deleted.
Maintain auditable evidence demonstrating compliance with established retention and disposal procedures.
Regularly assess retention policies to ensure continued compliance and effectiveness in mitigating data-related risks.

Relevant SOC 2 Criteria:

CC2.3 (Communication and Information): Addresses retention policies as part of information lifecycle management.
CC5.3 (Logical and Physical Access Controls): Ensures proper procedures for secure disposal of data.
PI1.4 (Use, Retention, and Disposal): Explicitly requires organizations to adhere to established retention and disposal policies for personal information, reinforcing privacy compliance.

Best Practices for Meeting ISO 27001 and SOC 2 Retention Requirements

Develop and document clear retention and disposal policies.
Train personnel on compliance requirements and their roles in maintaining data retention integrity.
Implement automated retention management tools to enforce policies consistently.
Conduct periodic reviews and audits to validate compliance with ISO 27001 and SOC 2 requirements.

Following these guidelines can help ensure organizations confidently demonstrate compliance, mitigate data retention and privacy risks, and maintain the trust of stakeholders and auditors alike. Read more on our blog posts https://www.opusguard.com/post/understanding-the-updates-to-iso270012022---retention-management-comes-of-age and https://www.opusguard.com/post/does-soc-2-mandate-data-retention-demand-deletion-of-your-old-data .

Disclaimer: The content provided by the Opus Guard Governance Library is for informational purposes only and does not constitute legal advice. While we strive to offer useful guidelines to assist your understanding and learning, it is important to consult legal counsel or authoritative sources for specific advice relevant to your circumstances.