Synthetic Users User Data Deletion and Retention Policy

1. Purpose

This policy defines how the vendor manages, retains, and permanently deletes user data collected and processed on behalf of the organization. It ensures compliance with applicable data protection laws (including GDPR and CCPA) and supports the organization’s privacy commitments.

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2. Data Mapping and Inventory

• The vendor shall maintain a complete and up-to-date inventory of all data processed on behalf of the organization.
• Each dataset must be classified according to sensitivity (e.g., personal, financial, confidential, operational).
• Data flows, storage locations, and transfer points shall be documented and reviewed at least annually.

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3. Data Retention Policy

• The vendor shall maintain a documented data retention schedule specifying:
  • Categories of data collected.
  • Purpose of processing.
  • Legal, contractual, and operational retention periods.
• Personal data shall not be retained longer than necessary for its original purpose.
• Upon expiry of the retention period, data shall be securely deleted or anonymized.
• Any exceptions (e.g., legal hold, dispute, or audit) must be documented and justified.

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4. Data Deletion Requests

• The vendor shall maintain a dedicated channel (email or web form) for receiving deletion requests from the organization or data subjects.
• Clear instructions for submitting deletion requests must be made available.
• The vendor shall log and acknowledge receipt of all deletion requests within five (5) business days.

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5. Verification of Requests

• The vendor shall implement a robust identity verification process to confirm the legitimacy of deletion requests and prevent unauthorized actions.
• Verification records shall be retained for audit purposes.

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6. Secure Data Deletion

• Valid deletion requests must trigger irreversible deletion using secure industry-standard methods such as cryptographic erasure or data shredding.
• Data must be deleted from:
  • Active systems and databases.
  • Logs and data lakes.
  • Replicated or cached environments.
  • Backups, following backup lifecycle policies (see section 8).
• The vendor shall ensure data is not recoverable post-deletion.

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7. Deletion Timeline

• All valid data deletion requests must be completed within 30 calendar days, unless legal or regulatory requirements specify otherwise.
• The requester shall receive notification of completion or justification for any delays.

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8. Backup and Archived Data

• The vendor shall ensure that personal data in backup or archived systems is either:
  • Deleted immediately upon restoration, or
  • Automatically purged during the next scheduled backup rotation (maximum retention: 90 days).
• Backups containing deleted data shall be encrypted and access-restricted until their deletion.

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9. Third-Party Processors

• The vendor shall ensure that all subcontractors and subprocessors follow equivalent data retention and deletion standards.
• Contracts must explicitly define data deletion obligations and audit rights.
• The vendor remains fully accountable for ensuring compliance.

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10. Confirmation and Reporting

• Upon completion of a deletion request, the vendor shall issue written confirmation to the organization specifying:
  • The data deleted.
  • The systems affected.
  • The date and method of deletion.
• Summary reports of deletion activities shall be available upon request.

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11. Auditing and Compliance

• The vendor shall conduct regular internal audits (at least annually) to ensure compliance with this policy.
• Audit reports must be retained and made available to the organization upon request or during regulatory inspections.
• Non-compliance incidents must be reported within 72 hours of discovery.

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12. Employee Training

• All employees and contractors with data access shall receive annual training on data retention, deletion procedures, and privacy best practices.
• Training completion must be tracked and documented.

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13. Physical Media and Hardware Disposal

• Any physical storage media (e.g., hard drives, USBs, servers) containing user data must be destroyed using secure disposal methods such as degaussing or physical shredding.
• Disposal actions must be logged and certified.

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14. Continuous Improvement

• The vendor shall periodically review and update this policy in line with evolving regulations, audit results, and best practices.
• Improvements must be communicated promptly to the organization.

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15. Recordkeeping

• Comprehensive records of all data deletion and retention actions shall be maintained for a minimum of three (3) years for audit and compliance verification.