Finance & Banking
Finance and banking firms are subject to strict record-keeping rules from regulators in both the US and UK. They must balance regulatory minimum retention periods (often measured in years) with data minimization principles for privacy. In collaborative platforms like Confluence and Jira, content might include policies, client communications, project documentation, and incident logs – all of which should be classified and retained appropriately. Below are suggested retention timeframes by data category, followed by key regulatory references and a best-practice checklist.
Suggested Retention Timeframes by Data Category (Finance)
Customer Records and Communications: 7 years minimum. This includes records of client transactions, advice, and communications relating to financial services. Rationale: Regulators often require at least 5 years – for example, the UK FCA (Financial Conduct Authority) aligned with MiFID II mandates a 5-year retention (extendable to 7) for transaction-related communications womblebonddickinson.com. U.S. SEC/FINRA rules similarly require 3–6 years for broker-dealer records laserfiche.com, so 7 years covers the strictest common requirement.
KYC and AML Documentation: 5 years after account closure. Know-Your-Customer forms, identity verification info, and Anti-Money Laundering records should be kept at least five years after the relationship ends finra.org. Rationale: Both U.S. and UK AML regulations (e.g. Bank Secrecy Act, FINRA Rule 3310 and UK Money Laundering Regulations) specify 5-year retention for customer identification data and transaction records to support AML monitoring finra.org.
Internal Policies, Compliance Reports, and Audit Records: 6 years. Retain Confluence pages or Jira tickets that document internal controls, audit project + findings, and compliance policies for six years from their last effective date. Rationale: Under U.S. laws like Sarbanes-Oxley and HIPAA (if applicable for financial health data), organizations must retain compliance documentation for at least 6 years givainc.com. This also aligns with typical regulatory exam cycles and ensures evidence is available as required for future audits.
General Project Documentation and Meeting Notes: 2–3 years (post-project). For routine project-related Confluence pages or Jira issues not containing regulated data, consider a shorter retention. Rationale: While not mandated by law, archiving or deleting stale project content after a couple of years helps maintain best-practice data hygiene and minimizes storage, costs, and confusion of outdated information. Ensure any project records that feed into financial reports or client deliverables are retained longer if needed for compliance or litigation.
Personal Data (PII) in notes or service tickets: As short as feasible, per GDPR. If Confluence and Jira content - particularly Jira Service Management - contains personal identifiable information (e.g. customer contact info or employee HR data), apply the GDPR’s “no longer than necessary” principle jatheon.com. For instance, delete or anonymize personal data once it’s no longer required for the task at hand (customer issue resolved, etc.), which might be far sooner than the general 5–7 year business record requirement.
Key Regulatory Guidance for Finance/Banking
US SEC/FINRA Rules: SEC Rule 17a-4 and FINRA rules require brokers to preserve key records 3–6 years. For example, trade confirmations, statements and communications are often 3 years, while account records and general ledgers are 6 years. WORM (write-once-read-many) or audit-trail storage may be required to ensure records are tamper-proof laserfiche.com.
UK FCA Recordkeeping: The FCA Handbook (e.g. COBS 4 and SYSC 9) imposes specific retention requirements. Most financial promotion records must be kept at least 3 years (or longer for certain products) mirrorweb.com, and MiFID-related communications 5 years (up to 7) womblebonddickinson.com. Appropriateness assessments and client records generally have 5-year minimum retention womblebonddickinson.com.
Anti-Money Laundering (AML): Both US and UK AML laws mandate retaining customer identification and transaction logs 5 years after account closure or transaction finra.org. Notably, a recent U.S. change now requires OFAC-related records for 10 years americascreditunions.org, so firms should track evolving requirements.
Privacy Regulations: Financial institutions handling personal data must also follow privacy laws. The EU GDPR (and UK DPA) requires data retention limits and right to erasure for customer personal data. This means, for instance, if customer PII appears in a Jira ticket or Confluence page, it should be deleted once it’s no longer needed for the purpose collected, notwithstanding financial recordkeeping rules. In the U.S., laws like the California Consumer Privacy Act (CCPA/CPRA) similarly expect businesses to honor deletion requests and not retain personal data beyond necessity.
Security Standards: Frameworks like SOC 2 and ISO/IEC 27001 include controls related to data retention. While they don’t prescribe exact timeframes, they require defining retention policies aligned with business/regulatory needs and ensuring secure disposal of data after that period https://www.opusguard.com/post/does-soc-2-mandate-data-retention-demand-deletion-of-your-old-data and https://www.opusguard.com/post/understanding-the-updates-to-iso270012022---retention-management-comes-of-age . Banks and fintech firms often seek SOC 2 certification, so demonstrating a documented retention schedule (and real-world adherence to it) is crucially important for compliance and audits.
Finance/Banking Retention Best-Practice Checklist
Classify and Label Content: Identify Confluence spaces and Jira projects that are likely to contain regulated financial records or personal data. Classify content by category (e.g. Client Communication, Internal Policy, General Reference) to attach the appropriate retention rule.
Apply Regulatory Minimums: Configure retention rules to meet or exceed the longest applicable legal requirement. For example, 7-year retention on any content that might constitute a business record of a transaction or advice (covering SEC’s 6-year rule and FCA’s 5-year rule with buffer) laserfiche.com womblebonddickinson.com. Never delete regulated records before the mandatory period expires.
Enforce Automatic Deletion/Archiving: Use tools (like Opus Guard’s Content Retention Manager) to automatically archive and later delete content once it reaches its retention date. For instance, Jira issues in a “Closed – older than 3 years” category could be purged quarterly. Ensure secure disposal – erased content should be unrecoverable in line with SEC audit-trail/WORM requirements laserfiche.com (Opus Guard ensures this).
Implement Legal Hold Procedures: Establish a process to suspend routine deletion for content that may be needed for litigation, investigations, or audits. If a lawsuit or regulatory investigation is anticipated, flag relevant custodian and non-custodial Confluence pages/Jira tickets with a Litigation Hold retention rule, so the retention tool does not delete them even if they hit their regular age limit.
Minimize Personal Data Exposure: Financial teams should avoid storing sensitive personal data in wiki pages or tickets unless necessary. If PII or customer data must be there, use minimal detail and remove it as soon as feasible. This supports GDPR obligations and reduces breach risk. For example, instead of writing a client’s full account number in a ticket, use a customer ID reference stored in a secure system, and when the ticket is no longer needed, ensure it is deleted routinely.
Regular Reviews and Updates: Review the retention policy at least annually. Regulations evolve (e.g. EU financial rules or new guidance from bodies like the FCA or FINRA) and business needs change. Update timeframes if laws change – for example, if a new rule extends a required retention from 5 to 10 years, adjust the policy promptly federalregister.gov. Likewise, incorporate any new content types users are creating in Confluence/Jira.
Audit and Monitor Compliance: Periodically audit a sample of content to ensure the retention rules are working (e.g. check that closed issues older than 3 years truly got deleted). Keep an audit log of deletions and archives – this evidences compliance to regulators and aligns with SOC 2 controls requiring proof of secure data handling bytebase.com.
Training and Awareness: Educate employees in finance and compliance teams about the retention policy. They should know how to classify content (e.g. mark something as a “record” if it needs long retention) and understand why old data will be purged. Emphasize that good recordkeeping and timely disposal of data both contribute to security and compliance (for example, fewer old records means fewer targets in a data breach).
Summary of Finance & Banking guidance
Table 1. Suggested Timeframes (by Classification / Space / Owner) | |
|---|---|
Customer Records & Communications | Classification = “Client Communication” → Retain 7 years |
KYC / AML Documentation | Classification = “Identity Verification” → Retain 5 years after account closure |
Compliance & Audit Records | Space = “Compliance” → Retain 6 years |
General Project Documentation | Space = “Internal Projects” → Retain 2–3 years post-completion |
Personal Data (PII) | Classification = “Contains PII” → Delete or anonymize as soon as purpose is complete (GDPR requirement) |
Table 2. Summary Checklist |
|---|
Map regulated records (e.g. client comms, AML/KYC) to classifications with defined minimums (5–7 years) |
Apply space-level rules: e.g. compliance spaces = 6 years, general projects = 3 years |
Enable legal hold override rules on users and spaces when litigation is anticipated |
Configure and ensure automatic deletion / archiving when document lifecycles expire |
Audit quarterly that expired records have been securely disposed of and review policies yearly |
By following these practices, finance and banking organizations can confidently use Confluence, Jira, and Rovo for accelerating teamwork collaboration while staying within the strict retention requirements of their regulators and maintaining strong information governance.