SI-12: Information Management and Retention

To meet the si-12: information management and retention requirement, you must define, implement, and prove a repeatable process to manage and retain system information and system outputs according to all applicable legal, regulatory, policy, and mission requirements, then dispose of information only when retention rules allow. This is a control-design plus evidence problem, not a tooling problem. ¹

Key takeaways:

• Build a retention schedule that maps information types to retention rules, owners, and locations.
• Enforce retention with technical controls (immutability, holds, backups) and procedures (legal hold, exceptions, disposition).
• Keep audit-ready evidence: policies, mappings, system configurations, holds, and disposition logs.

SI-12 is where “records management,” “logging,” “backups,” and “data lifecycle” collide. The control is short, but the operational blast radius is wide: it applies to information stored inside the system and information the system produces (reports, exports, tickets, logs, notifications, derived datasets). Your job as a Compliance Officer, CCO, or GRC lead is to translate a pile of overlapping obligations into a single retention program that engineers and business owners can follow without improvising.

The fastest path is to treat SI-12 as a governed lifecycle: identify information types, assign ownership, define retention and disposal rules, implement enforcement points, and prove it with durable evidence. Most SI-12 findings come from gaps in mapping (nobody can say what the retention rule is), gaps in execution (rules exist but aren’t enforced in systems), or gaps in evidence (you can’t show what happened during an audit window).

This page gives requirement-level implementation guidance you can operationalize quickly for federal information systems and contractor systems handling federal data. ²

Regulatory text

Requirement (SI-12): “Manage and retain information within the system and information output from the system in accordance with applicable laws, executive orders, directives, regulations, policies, standards, guidelines and operational requirements.” ¹

What the operator must do:
You must (1) determine what rules apply to your system’s information and outputs, (2) implement retention and management mechanisms that follow those rules, and (3) maintain evidence that retention and disposition are executed as designed. SI-12 does not hand you a specific retention period; it requires a defensible method for setting and enforcing the right periods.

Plain-English interpretation

SI-12 means: Nothing important disappears early, nothing sensitive lives forever without a reason, and you can prove both.
Operationally, you are expected to:

• Know what information you have (including exports and derived outputs).
• Know which rules apply (contract clauses, agency policy, internal policy, operational needs).
• Keep information for the required duration, protect it while retained, and dispose of it when allowed.
• Freeze disposition when needed (legal hold or investigation hold) and document exceptions.

Who it applies to (entity and operational context)

SI-12 is directly relevant for:

• Federal information systems operated by agencies. ²
• Contractor systems handling federal data, including cloud and SaaS environments processing federal information under contract. ²

Operational contexts where SI-12 becomes high-friction:

• Systems with multiple data stores (SaaS + data lake + SIEM + ticketing + collaboration tools).
• Products with self-service export features (CSV downloads, bulk APIs).
• Environments with heavy logging/telemetry (security logs, application logs, audit trails).
• Third-party managed platforms where retention defaults may conflict with your obligations.

What you actually need to do (step-by-step)

1) Assign ownership and decision rights

Create a simple RACI for retention:

• Control owner (GRC): defines requirement mapping, evidence, and review cadence.
• Data/records owner (Business): approves retention rules by information type.
• System owner (IT/Engineering): implements configuration and access controls.
• Legal (as needed): approves legal hold triggers and exception handling. Document named owners. Auditors look for accountability before they look for tooling.

2) Inventory “information” and “information output from the system”

Build an inventory that is specific enough to enforce:

• Information types: customer records, HR data, case files, configs, secrets, keys, logs, metrics, audit trails.
• Outputs: generated reports, billing statements, exported datasets, emails/notifications generated by the system, API exports, tickets created in downstream tools.
• Storage locations: primary database, object storage, file shares, endpoints, backup repositories, SaaS (email, chat, ticketing), SIEM, analytics warehouse. Deliverable: a Retention Data Map (table) that connects information types to systems and outputs.

3) Identify applicable requirements and translate them into retention rules

SI-12 explicitly points to “applicable” external and internal drivers. ¹
Create a Retention Authority Register that lists:

• The requirement source (contract/policy/standard/internal operational requirement).
• The information types it governs.
• Required retention rule (duration/event-based trigger) and disposal constraints. Avoid hardcoding numbers in multiple places. Put the rule in one “source of truth” table, then reference it.

4) Publish a retention schedule and disposition standard

Minimum artifacts:

• Information Management & Retention Policy (scope, roles, legal hold, exceptions).
• Retention Schedule (table by information type).
• Disposition Standard (how deletion works, how you verify deletion, how you handle backups, how you document it). Key design decision: define retention using events where possible (e.g., “after case closure,” “after contract end,” “after account termination”) to align with operations.

5) Implement enforcement points in systems (not just documents)

Common enforcement mechanisms by data class:

• Application/database: TTL fields where appropriate, scheduled purge jobs, retention flags, role-based deletion rights.
• Object storage: bucket lifecycle policies, WORM/immutability for regulated records, versioning where required.
• Logs/SIEM: log retention configuration, archive tiers, protected audit logs where applicable.
• Backups: retention policies, immutable backup vault options, restore testing; document how retention interacts with backups (deleting primary data does not always delete backup copies immediately).
• Exports: watermarking, access control, export logs, and defined retention for generated output repositories. Auditors expect that the retention schedule is “wired into” the environment, not left to user behavior.

6) Implement legal hold and investigation hold workflow

Define:

• Who can place a hold, and under what triggers.
• What systems are in scope for a hold (primary storage, exports, logs, backups).
• How you technically enforce it (prevent purge jobs from deleting held items; isolate held data).
• How you release holds and resume disposition. Keep hold records durable and access-controlled.

7) Define recurring operations: review, testing, and exception handling

Add three operating rhythms:

• Retention rule review: revalidate rules when contracts change, system features add new outputs, or new storage locations are introduced.
• Disposition testing: sample-check that purge jobs ran, that objects moved tiers correctly, and that holds prevented deletion.
• Exception management: document approved deviations (e.g., longer retention for an investigation) with owner and rationale.

8) Prove it with evidence (assessment-ready)

This is the SI-12 failure mode called out in practice: missing implementation evidence. ¹
Operationalize evidence collection as a recurring task, not a scramble.

How Daydream fits naturally: Daydream is useful when you need SI-12 to stop being a paragraph in a control catalog and become a tracked requirement with (1) a control owner, (2) an implementation procedure, and (3) recurring evidence artifacts tied to each system and information type. That mapping is a recommended best practice for assessment readiness. ¹

Required evidence and artifacts to retain

Keep evidence that answers: “What is the rule, where is it enforced, and did it run?”

Governance

• Approved retention policy and standards (versioned).
• Retention schedule (information type → rule → owner → systems).
• Retention authority register (what drove each rule).
• RACI and control ownership assignment.

Technical configuration evidence

• Screenshots/exports of lifecycle policies (object storage, SaaS retention settings).
• Database/application purge job configuration and code references (change-controlled).
• SIEM/log platform retention configuration and archive settings.
• Backup retention policies and immutability configuration (where used).

Operational run evidence

• Purge job run logs, deletion reports, or system-generated audit logs.
• Samples showing records aged out according to rule.
• Legal hold tickets/approvals, hold scope, hold release records.
• Exception approvals and compensating controls.

Common exam/audit questions and hangups

Auditors and assessors tend to ask:

• “Show me your retention schedule. Who approved it?”
• “Which systems store this information type, including exports and reports?”
• “How do you prevent deletion when there is a legal hold?”
• “How do you handle retention for backups and archives?”
• “Prove the rule is enforced: show logs/config and a sample of records disposed.”
• “What changed since the last assessment? Any new outputs (APIs, exports, analytics)?”

Hangups that slow teams down:

• “We have a policy” but no mapping from policy to systems and outputs.
• Retention in the primary system is configured, but downstream systems (ticketing, SIEM, analytics) drift.

Frequent implementation mistakes and how to avoid them

1. Treating SI-12 as a records-management-only task
   Fix: include logs, analytics, exports, and derived data in the inventory.

2. Relying on manual deletion
   Fix: implement automated lifecycle rules and restrict delete privileges.

3. Ignoring backups
   Fix: document backup retention and how disposition requests affect backup copies. Make the limitation explicit and approved.

4. No legal hold mechanism
   Fix: implement a hold workflow tied to technical controls. A policy statement alone does not stop purge jobs.

5. Evidence built after the fact
   Fix: define an evidence pack and collect it on a schedule. Daydream-style mapping of owner, procedure, and recurring artifacts reduces this risk. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for SI-12, so this page does not cite specific actions. Practically, SI-12 failures show up as:

• Investigation friction: you cannot produce required records fast, or records are incomplete.
• Security exposure: sensitive data is retained longer than needed and becomes breach scope.
• Contract/compliance risk: inability to demonstrate retention controls can become an audit finding that blocks authorization or renewal.

Practical 30/60/90-day execution plan

First 30 days (stabilize and map)

• Assign SI-12 control owner and system owners; publish RACI.
• Build the first-pass Retention Data Map: information types, outputs, and storage locations.
• Draft retention schedule structure and retention authority register.
• Identify the top systems where retention is most likely to fail (exports, logs, backups).

Days 31–60 (implement and enforce)

• Approve policy + retention schedule with business and legal stakeholders as needed.
• Configure retention in priority systems (object storage lifecycle, log retention, backup retention).
• Implement legal hold workflow and define hold scope across systems.
• Define evidence pack and start collecting configuration exports and run logs.

Days 61–90 (prove and operationalize)

• Run disposition tests and document results; fix gaps.
• Perform an exception review: anything retained outside the schedule needs approval and tracking.
• Add retention checks to change management for new features that create outputs (reports/APIs/exports).
• Move SI-12 evidence to a recurring cadence with named owners and due dates.

Frequently Asked Questions

Does SI-12 require specific retention periods?

No. SI-12 requires retention aligned to applicable laws, directives, policies, standards, and operational needs, then expects you to implement and prove those rules. ¹

What counts as “information output from the system”?

Treat exports, generated reports, notifications, downstream tickets, and derived datasets as outputs. If the system creates it and it can be stored, it needs a retention rule and a storage location in your data map.

How do we handle retention for SaaS tools managed by a third party?

Put the SaaS platform in scope as a storage location, configure retention settings where possible, and document compensating controls where the platform cannot meet your schedule. Contract terms should support required retention and legal hold needs.

Are backups in scope for SI-12?

Yes in practice, because backups store system information. Document backup retention rules, how they align to the schedule, and what happens when you must preserve or dispose of data that may exist in backup copies.

What evidence is most persuasive in an audit?

A clear retention schedule mapped to systems, plus configuration exports and run logs showing retention actions occurred. Pair that with legal hold records and exception approvals for anything outside standard rules.

How can Daydream help operationalize SI-12 without turning this into a long project?

Use Daydream to map SI-12 to a named control owner, a concrete implementation procedure, and a recurring evidence checklist per system. That structure matches recommended best practice and reduces the “we can’t prove it” failure mode. ¹

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5