The entity retains personal information consistent with its objectives

SOC 2 Privacy criteria expect you to keep personal information only as long as it serves your stated objectives. In practice, this requirement fails when retention is informal (“we keep it forever”), fragmented (each team decides), or incomplete (production deletes, but backups and analytics keep copies indefinitely).

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat retention as a controlled lifecycle: (1) define purposes and data categories, (2) map where the data lives, (3) set retention rules per category/location, (4) implement deletion and exception workflows, and (5) keep operating evidence. You are building a record that shows your retention choices are deliberate, approved, implemented, and monitored.

This page gives requirement-level implementation guidance you can execute quickly: who is in scope, what to build, what evidence to retain, common auditor questions, and a practical 30/60/90-day plan. The goal is to pass scrutiny without over-engineering, while reducing privacy and breach exposure from unnecessary data accumulation.

Regulatory text

Requirement (SOC 2 Privacy, TSC-P3.2): “The entity retains personal information consistent with its objectives.” ¹

Operator meaning: You must be able to show, for each type of personal information you collect or receive, that you (a) know why you keep it, (b) keep it only as long as that purpose requires (plus any documented legal/contractual need), and (c) can carry out deletion in practice. “Objectives” are your business purposes and your commitments in privacy notices, contracts, and internal policies.

Plain-English interpretation

This requirement is a retention discipline requirement, not a storage optimization project.

You pass TSC-P3.2 when you can answer these questions with evidence:

• What personal information do we have, and where is it stored?
• Why do we keep each category (objective/purpose)?
• How long do we keep it, by system and by record type?
• What triggers deletion, and who is accountable?
• How do we handle exceptions (legal hold, disputes, security investigations)?
• How do we ensure third parties follow equivalent retention instructions?

If your current posture is “we delete on request sometimes,” you are not meeting the requirement. SOC 2 expects retention to be defined and consistently executed.

Who it applies to (scope and operational context)

Applies to: Service organizations seeking SOC 2 reporting that collect, store, process, or transmit personal information about customers, end users, employees, contractors, or other individuals ¹.

Typically in scope data and systems

• Product databases containing end-user profile data, identifiers, communications, or usage history
• Support platforms (ticketing, chat transcripts, call recordings)
• Billing/finance systems that contain payer contact details and transaction records
• HR/people systems (employee and applicant data)
• Logs/telemetry that can identify a person or device tied to a person
• Data warehouses, analytics tools, and event streams
• Backups, archives, and disaster recovery replicas
• Third parties processing personal information (cloud hosting, CRM, support tools, analytics, payroll)

Operational trigger points that create audit exposure

• New product features that start collecting new fields
• Migrations into data warehouses or long-term logging platforms
• New third parties added without retention clauses
• “Temporary” exports into spreadsheets or shared drives
• M&A or legacy systems kept “just in case”

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

Step 1: Define “objectives” in a retention context

Create a short list of approved objectives that justify retaining personal information. Keep it concrete:

• Provide the service (account administration, feature delivery)
• Security and fraud detection
• Customer support and dispute resolution
• Billing, tax, and accounting operations
• Product improvement (where permitted by your commitments)
• Legal/regulatory obligations (where applicable to your business)

Then link those objectives to your public privacy notice and customer agreements. Misalignment is a common audit hangup: your notice may promise shorter retention than engineering actually implements.

Step 2: Build a personal information inventory tied to systems

You need an inventory that is usable for retention operations, not a one-time spreadsheet.

Minimum fields:

• Data category (e.g., account identifiers, contact info, support content, usage events)
• Data subjects (customers, end users, employees)
• Source (collected from user, from customer admin, generated by system)
• Systems/locations (prod DB, warehouse, logs, backups, SaaS tools)
• Objective/purpose
• Retention rule (duration or condition-based trigger)
• Disposal method (hard delete, anonymize, aggregate, tokenization)
• Owner (business + technical)

Practical tip: start with your highest-risk systems (core prod DB, support tool, data warehouse, logs). Expand.

Step 3: Set retention rules that are implementable

Write a retention schedule that engineers can implement. Use one of two patterns:

Pattern A: Time-based retention

• “Keep support tickets for X time after closure.”
• “Keep failed login logs for X time.”

Pattern B: Event-based retention

• “Delete account data X time after account closure.”
• “Delete applicant data after hiring decision, unless consented for future roles.”

For SOC 2, the most important trait is defensibility: each rule must map to an objective, and exceptions must be documented and controlled.

Step 4: Operationalize deletion across the full data lifecycle

Most teams delete in one place and forget the copies. Build an end-to-end “deletion coverage map”:

1. Primary systems (systems of record)

• Implement scheduled jobs or lifecycle policies that enforce retention (database TTL, object storage lifecycle rules, application-level deletion workflows).
• Log deletion actions with ticket IDs or run IDs.

2. Derived data (warehouses, analytics, search indexes)

• Define whether you delete, anonymize, or re-key records.
• Ensure downstream datasets inherit deletion signals.

3. Logs and monitoring

• Confirm log retention settings in observability tools.
• Validate that personal data is minimized in logs; retention is harder when logs contain raw identifiers.

4. Backups and archives

• Document backup retention periods and restoration procedures.
• If backups are immutable, document compensating controls: short backup retention, restricted restore access, and restoration playbooks that re-apply deletions after restore.

5. Third parties

• Contractually require retention limits and deletion support.
• Maintain a mechanism to request deletion and track completion (tickets, vendor portal confirmations, attestations).

Step 5: Add governance: exceptions, legal hold, and approvals

Auditors expect controlled exceptions. Implement:

• Exception request (what data, why, how long, risk assessment)
• Approval (legal/compliance + data owner)
• Review cadence (periodic confirmation that the exception still applies)
• Legal hold workflow (triggered by litigation, investigation, or regulatory inquiry)

Step 6: Monitor and keep operating evidence

Define lightweight monitoring that proves ongoing operation:

• Monthly (or periodic) report of deletions executed, exceptions granted, and overdue items
• Spot checks: sample records past retention to confirm deletion
• Change management: when new personal data fields are introduced, retention rules must be updated

If you use Daydream to run control checklists and evidence collection, structure TSC-P3.2 around recurring tasks: retention schedule review, system configuration screenshots/exports, deletion job logs, and third-party confirmations. The product value is consistency and audit-ready packaging, not new policy text.

Required evidence and artifacts to retain

Keep these artifacts in an audit repository with clear dates and owners:

Policy and governance

• Data retention and disposal policy aligned to objectives ¹
• Retention schedule (by data category and system)
• Exception and legal hold procedure
• Records of approvals for retention rules and exceptions

Operational evidence

• Data inventory / data map showing personal information locations
• System configuration exports or screenshots showing retention settings (SaaS admin pages, lifecycle rules, log retention)
• Deletion job run logs, ticketing records, or change records demonstrating execution
• Sample-based testing results (your internal control test notes)

Third-party evidence

• Contract clauses or addenda covering retention/deletion support
• Completed deletion requests and vendor confirmations
• Third-party risk documentation showing retention was assessed for in-scope processors

Common exam/audit questions and hangups

Auditors and customers will probe for gaps. Expect:

1. “Show me your objectives and how they map to retention periods.”
   Hangup: retention rules exist but no documented purpose, or purpose conflicts with privacy statements.

2. “Where else does this data exist besides the main database?”
   Hangup: warehouses, analytics, logs, and backups are missing from scope.

3. “Demonstrate deletion actually happens.”
   Hangup: policy-only controls without operating evidence (no logs, no tickets, no configuration proof).

4. “How do you handle backups and restores?”
   Hangup: indefinite backup retention or no documented process to re-apply deletions after restoration.

5. “How do your third parties delete data?”
   Hangup: contracts omit retention requirements; deletion requests are ad hoc.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Retention schedule is generic (one period for everything)	Not “consistent with objectives” for different data types	Create categories and map each to a purpose and rule
Only production deletion is implemented	Copies persist in analytics/logs/backups	Build a deletion coverage map per system class
No exception process	Teams keep data indefinitely “just in case”	Add exception approvals with time limits and reviews
Third parties not included	Data persists outside your control boundary	Add retention clauses and track deletion confirmations
No operating evidence	SOC 2 requires proof of operation	Capture config exports + deletion run logs + samples

Risk implications (why operators care)

Over-retention increases:

• Privacy risk: you hold data longer than promised or necessary.
• Incident impact: more personal information exposed if breached.
• Response cost: DSARs, deletion requests, and investigations become harder when data sprawl is uncontrolled.
• SOC 2 report risk: auditors may report exceptions if retention is undocumented or inconsistently enforced ¹.

Practical 30/60/90-day execution plan

Day 0–30: Define and inventory

• Assign owners: Privacy/Compliance for policy, Engineering/Data for implementation, Procurement for third parties.
• Draft or refresh retention and disposal policy tied to objectives ¹.
• Build the first-pass inventory for core systems: prod DB, support platform, data warehouse, logging tool, backups.
• Identify “quick wins”: SaaS retention settings already available but not set.

Deliverables: objectives list, retention policy, baseline inventory, initial retention schedule draft.

Day 31–60: Implement and prove operation

• Configure retention settings in logging/observability and SaaS tools; capture evidence.
• Implement deletion jobs or lifecycle rules for the highest-risk categories.
• Create exception + legal hold workflow in your ticketing system.
• Update third-party contracts/templates with retention and deletion requirements; start with highest-impact processors.

Deliverables: system configurations, deletion run logs, exception workflow, updated contract language or addenda plan.

Day 61–90: Close edge cases and make it repeatable

• Extend coverage to derived systems: search indexes, caches, data marts, ML feature stores.
• Document backup retention and restore procedures, including how deletions are handled post-restore.
• Run an internal control test: sample records past retention across systems and document results.
• Package audit evidence in a single binder (Daydream can act as the evidence hub and task runner).

Deliverables: deletion coverage map, backup/restore retention memo, testing results, audit-ready evidence set.

Frequently Asked Questions

Do we need a specific retention period to satisfy TSC-P3.2?

No single period is mandated by SOC 2. You need retention rules that are justified by your documented objectives and can be shown to operate consistently ¹.

How do we handle “delete” when backups are immutable?

Document backup retention limits, restrict restore access, and document a restore playbook that re-applies deletions after restoration. Auditors mainly want to see that backups are in your retention design and not ignored.

Does anonymization count as disposal?

It can, if the result is no longer personal information in your context. Document the method (what fields are removed or transformed) and ensure the process is repeatable and validated.

Are application logs considered personal information?

If logs can identify or be linked to an individual (directly or indirectly), treat them as personal information for retention purposes. Reduce what you log and set explicit log retention settings.

What evidence is most persuasive in a SOC 2 audit for this requirement?

A retention schedule mapped to objectives, system configuration proof of retention settings, and operating evidence that deletion occurred (job logs, tickets, samples) are usually the fastest way to demonstrate operation ¹.

How should we address third parties that cannot delete specific data on request?

Treat it as a risk decision: document the limitation, add contractual commitments where possible, implement compensating controls (short retention, encryption, access restrictions), and consider alternate providers for sensitive data.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. AICPA TSC 2017