TSC-P3.2 Guidance

TSC-P3.2 requires you to keep personal information only as long as your business purpose and privacy commitments justify, then dispose of it securely. To operationalize the tsc-p3.2 guidance requirement, define retention periods per data type and system, implement deletion/archival workflows, and retain audit-ready evidence that the policy is followed and reviewed.

Key takeaways:

• Write a retention schedule tied to stated objectives (product, legal, customer commitments) and apply it to every system that stores personal information.
• Implement repeatable deletion/archival controls with logs, exceptions, and approvals that auditors can test.
• Prove operation: inventories, retention mappings, deletion evidence, and periodic reviews are the difference between “policy exists” and “control works.”

TSC-P3.2 sits in the SOC 2 Privacy criteria and focuses on a deceptively narrow question: are you retaining personal information in a way that matches what you say you do and what you need to do? The audit risk is rarely a total lack of a policy. The audit risk is mismatch: teams keep data “just in case,” systems retain by default, backups are ignored, and exception handling is informal.

A practical program for the tsc-p3.2 guidance requirement has three layers. First, a clear retention objective: why you keep each category of personal information, for how long, and where that commitment is documented (privacy notice, customer contract, internal policy). Second, technical and operational execution: automated retention where possible, manual procedures where necessary, and controls for hard-to-delete environments like logs, analytics platforms, and backups. Third, evidence: auditors test what happened during the audit period, not what you intended to do.

This page gives requirement-level steps to build a retention schedule, deploy controls across systems and third parties, handle exceptions, and package evidence for SOC 2 testing.

Regulatory text

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

Operator meaning:
You must be able to explain, implement, and evidence that (1) you keep personal information only for defined purposes aligned to your stated objectives, and (2) you dispose of it (or de-identify it) when those purposes no longer apply. Auditors will expect consistency between your internal objectives (business needs, contractual commitments, legal/regulatory drivers you’ve adopted) and what actually happens in systems.

Plain-English interpretation

• If you cannot name the purpose for keeping a specific personal data element, you should not keep it.
• If you can name the purpose, you still need a defined retention period (or retention logic) and a deletion/disposal method.
• “Consistent with objectives” means consistent with what you publicly commit to (privacy notice), what customers contract for, and what internal governance documents approve. ¹

Who it applies to

Entities

• Any organization undergoing a SOC 2 audit that includes the Privacy category and uses personal information in scope. ¹

Operational context (where this bites in practice)

• SaaS and platforms storing end-user data, customer contact data, and support content.
• HR and recruiting systems holding applicant and employee personal information.
• Marketing systems (CRM, email platforms) retaining leads long after inactivity.
• Security telemetry and application logs that accidentally contain personal information.
• Third parties that store or process personal information on your behalf (cloud hosting, customer support tools, analytics providers).

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

Step 1: Define “objectives” for retention (make them auditable)

Create a short statement that explains why personal information is retained in your environment. Keep it concrete:

• Deliver the service (account creation, authentication, core functionality)
• Support and customer success (tickets, call recordings, troubleshooting artifacts)
• Security (fraud detection, incident investigation)
• Finance (billing, invoices, payment reconciliation)
• Product improvement (analytics, bug diagnosis)

Then map where these objectives are expressed: privacy notice, MSA/DPA, internal policy. Auditors will ask you to reconcile conflicts.

Artifact: Retention objectives statement owned by Legal/Privacy + Security + Product.

Step 2: Build a personal information inventory tied to systems

You cannot enforce retention without knowing where personal information lives.

• Enumerate systems in scope (production DBs, data warehouse, logs, backups, CRM, support tools).
• For each system, identify personal information categories stored (customer contact info, identifiers, device data, support attachments, HR data).
• Identify the system owner and deletion mechanism (API deletion, admin UI, DB job, vendor ticket).

Artifact: Data inventory (system-by-system) with owners and deletion methods.

Step 3: Create a retention schedule (category → period → disposition)

For each personal information category:

• Retention rule: “Keep for X until Y event” (examples: “until account deletion,” “until contract termination plus defined period,” “until ticket closure plus defined period”).
• Disposition method: delete, anonymize, aggregate, archive with access restrictions.
• Scope: list systems where the rule applies.
• Exception path: legal hold, security investigation, contractual requirement.

Keep the schedule readable. Auditors want to test it. Engineers need to implement it.

Artifact: Retention schedule approved by the right authority (often Legal/Privacy + Security).

Step 4: Implement enforcement controls by system (automation first)

Prioritize systems with the most personal information and the hardest deletion paths.

Common control patterns auditors accept:

• Automated retention jobs: scheduled deletion/anonymization based on timestamps, status, or tenant lifecycle events.
• Tenant offboarding workflow: account closure triggers deletion across dependent systems.
• Access-controlled archives: where deletion isn’t feasible, move records to restricted storage with clear retention and purge.
• Log hygiene: prevent personal information from entering logs; set log retention aligned to security objectives.

For each system, write a short operating procedure:

• What triggers deletion
• Who approves exceptions
• How you confirm completion (logs, reports, tickets)

Artifacts: SOPs per system, configuration screenshots, job definitions, runbooks.

Step 5: Cover backups, replicas, and downstream analytics explicitly

SOC 2 auditors often focus here because teams forget it.

• Document whether backups are overwritten on a schedule and how restoration affects deleted records.
• Address data warehouse retention separately from source systems.
• Ensure deletion requests propagate, or document compensating controls (restricted access + purge at defined intervals).

Artifact: “Retention in backups and analytics” memo that explains your approach and evidence sources.

Step 6: Add monitoring, review, and exceptions management

TSC-P3.2 is not satisfied by a one-time implementation. You need periodic review.

• Monitor deletion job success/failure and track remediation.
• Maintain an exceptions register (legal holds, investigations, contract-driven retention).
• Review the retention schedule when objectives change (new product features, new markets, updated privacy notice).

Artifacts: Monitoring dashboards/export, exception log, review meeting notes and approvals.

Step 7: Prepare for audit testing (prove operation during the period)

Auditors test samples. Build a repeatable evidence pack:

• For a set of closed accounts/tickets, show deletion/anonymization occurred in each in-scope system.
• For retention jobs, show run history and completion logs.
• For exceptions, show approvals and end dates.

Tip: If you run this evidence pack monthly, SOC 2 fieldwork becomes confirmation, not archaeology.

Required evidence and artifacts to retain

Use this as your audit request checklist:

Evidence item	What it proves	Typical owner
Retention policy + retention schedule	Documented control design for retention aligned to objectives	Privacy/Legal + Security
System/data inventory	Completeness: you know where personal information resides	GRC + IT/Engineering
System SOPs / runbooks	Operational procedure and accountability	System owners
Deletion/anonymization job configs	Control implementation	Engineering/IT
Job run logs / reports	Control operation during audit period	Engineering/IT
Sample deletion tickets or automated events	End-to-end execution	Support/Ops/Engineering
Exceptions register (legal hold, investigations)	Controlled deviations with approvals	Legal + Security
Periodic review evidence	Ongoing governance	GRC/Privacy

Common exam/audit questions and hangups

Auditors commonly press on these points ¹:

• “Show me your objectives.” Where are they documented, and how do they justify retention durations?
• “How do you ensure deletion actually happens?” Policies without system enforcement fail quickly.
• “What about logs and backups?” If you can’t delete from backups, explain the overwrite cycle and access controls.
• “How do third parties handle retention?” Can you demonstrate that your instructions and contracts align with your objectives?
• “Prove it with samples.” Provide evidence for selected records from creation through disposition.

Frequent implementation mistakes and how to avoid them

1. Writing a retention policy without a system-by-system plan
   Fix: add system owners, deletion mechanisms, and monitoring per system.

2. Ignoring derived data and duplicates (exports, data warehouse tables, support attachments)
   Fix: inventory downstream stores and define disposition for each.

3. No exception governance (legal holds done over email, no end dates)
   Fix: create an exceptions register with approval, rationale, and review cadence.

4. Relying on “we can delete if asked”
   Fix: define proactive retention rules, not just reactive DSAR handling. Auditors expect the control to operate without a request.

5. No evidence pack
   Fix: produce a monthly deletion report and retain it; pair it with a sample set of deletion events.

Enforcement context and risk implications

SOC 2 is an audit framework rather than a regulator-driven enforcement regime. Your direct “penalty” is audit impact: retention gaps often become SOC 2 exceptions, qualified opinions, or scope limitations if you cannot evidence operation against TSC-P3.2. ¹
Operationally, over-retention increases exposure during security incidents, litigation, and customer disputes because more personal information remains accessible across more systems.

Practical 30/60/90-day execution plan

Day 0–30: Design the control and define scope

• Confirm Privacy criteria and systems in SOC 2 scope.
• Draft retention objectives statement and get Legal/Privacy sign-off.
• Build the system inventory for personal information stores (include third parties).
• Draft the retention schedule for top data categories (customer account data, support tickets, CRM contacts, logs).

Deliverables: retention objectives, inventory v1, retention schedule v1, named control owners.

Day 31–60: Implement and document enforcement in priority systems

• Implement deletion/anonymization workflows for the highest-risk systems.
• Write SOPs/runbooks per system and define evidence outputs.
• Add monitoring/alerts for job failures.
• Stand up an exceptions register with approval workflow.

Deliverables: operating procedures, deletion job configs, monitoring evidence, exceptions register.

Day 61–90: Prove operation and prepare the audit packet

• Run retention controls on a recurring basis and retain logs/reports.
• Perform an internal effectiveness check: sample records and trace deletion across systems.
• Fix gaps found in backups, analytics, and third parties.
• Package evidence for auditors: policy, schedule, inventory, samples, and review minutes.

Deliverables: evidence pack, internal test results, remediation tickets, review sign-off.

Where Daydream fits (only if you need speed and audit-ready evidence)

If you’re struggling with completeness (missing systems) or evidence collection (screenshots, logs, samples), Daydream can act as the system of record for your retention schedule, link it to your data inventory and third parties, and generate an audit-ready evidence pack from recurring control runs. Use it to keep owners accountable and avoid last-minute evidence hunts.

Frequently Asked Questions

Does TSC-P3.2 require specific retention periods (like “7 years”)?

No specific duration is stated in the criterion. You set retention to match your documented objectives, then prove you follow it. ¹

Are backups in scope for retention testing?

Auditors commonly ask how deleted records behave in backups and whether backups overwrite on a defined cycle. If deletion from backups is not feasible, document compensating controls and purge/overwrite behavior you can evidence. ¹

How should we handle security logs that may contain personal information?

Start by preventing personal information from being logged through logging standards and scrubbing. Then set log retention based on your security objective and implement deletion or overwrite controls with monitoring and evidence.

What’s the minimum evidence auditors will accept?

Expect to provide the retention policy/schedule, a data/system inventory, and operating evidence (job logs, tickets, or reports) that shows retention actions occurred during the audit period. ¹

Do third parties need to follow our retention schedule?

If a third party stores or processes personal information for you, your objectives and commitments still apply. Contract terms, configuration settings, and offboarding procedures should align to your retention schedule, and you should retain evidence.

We only delete data when customers ask. Is that enough?

Usually not for SOC 2 Privacy scope. TSC-P3.2 expects retention consistent with objectives as a standing practice, which implies proactive retention rules and disposal, not only reactive deletion requests. ¹

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 Trust Services Criteria 2017