Data Management
How Long Should You Keep Personal Data?
How Jamaican businesses should decide retention periods, build a retention schedule and dispose of personal data securely under the Data Protection Act.
What you will learn
- Why keeping data indefinitely is a risk
- What a retention schedule documents
- Why retention periods should not be invented
- How to dispose of data appropriately
A common business practice is "keep everything just in case." That creates privacy and security risk.
One of the fundamental data-protection principles is that personal information should not be retained longer than necessary for the purpose for which it is processed, subject to applicable legal requirements.
What is a retention schedule?
A retention schedule documents:
- What information do we have?
- Why do we keep it?
- How long do we keep it?
- What starts the retention period?
- Is another law relevant?
- What happens when the period ends?
Example
Instead of "Employee files, keep indefinitely," a proper record might state:
- Record: Job applications from unsuccessful candidates
- Purpose: Recruitment
- Retention: the organisation determines an appropriate period
- Trigger: Completion of recruitment exercise
- Disposal: Secure deletion or shredding
Retention periods should not be invented
Jamaica Privacy Hub should never automatically claim that every category must be retained for a particular number of years. Different legislation, contractual requirements, limitation periods and legitimate business needs may affect retention. The platform helps the business determine and document the appropriate rule.
Disposal matters too
At the end of retention, determine whether information should be:
- securely deleted;
- physically destroyed;
- anonymised; or
- otherwise disposed of appropriately.
Simply placing files in a normal computer recycle bin may not constitute appropriate secure disposal.
Put this into practice
Capture retention rules for each activity and export a retention schedule.
Build My Retention ScheduleFrequently asked questions
Key takeaways
- Personal data should not be kept longer than necessary for its purpose, subject to legal requirements.
- A retention schedule records what you hold, why, how long, the trigger and how to dispose of it.
- Retention periods should be determined from real needs and law, not invented.
- Disposal matters, secure deletion or destruction is not the same as a recycle bin.
