Retention, archiving and deletion

1. Regulatory Concept & Core Standards

This video focuses on how to apply the specific national retention rule. Follow the sequence of decisions in the example rather than simply memorising a list. Notice who is involved, what information is needed and the expected result. These points help turn the content into a practice that another person can verify. The GDPR applies alongside national reporting provisions. Collection, access and retention need purpose and legal basis. Protection also concerns people named in the report, without removing lawful confidentiality safeguards.

The GDPR does not prescribe one period for every file. Apply the specific requirements of the relevant legislation. Pending proceedings and statutory starting events affect deletion.

Apply the following rule: Section 19(1) requires personal data collected when receiving reports to be deleted within three months after the procedure is completed. If judicial or disciplinary proceedings against the person concerned or the reporting person have begun, keep the data throughout those proceedings, including an appeal or objection, and delete after one year has passed following their completion. This specific rule also applies to national-law reporting through the cross-references in sections 34 and 35. Do not replace it with an unspecified necessary-and-proportionate period.

2. Practical Implementation & Procedure

Use the national overview. Record completion, pending matters and review. Include copies and exports, documenting secure deletion. Before moving on, turn this procedure into a sequence you could explain to a colleague. Identify the first check, the action that depends on its outcome and the record that allows the decision to be reconstructed. Follow the sequence on screen and identify the point where an error would change the result.

Consider how a colleague taking over tomorrow would understand the decision. Identify the verified information and its source, who is authorised to decide and who checks the result. The record should connect the decision to the material actually used rather than repeat the whole file. State critical gaps and assign a specific action to resolve them. This makes continuity independent of one person’s memory. Apply the proposed organisational steps within legal powers. In the case, distinguish observation, conclusion and hypothesis. An observation describes available evidence, a conclusion explains what can reasonably be inferred and a hypothesis still needs checking. Do not infer motives merely from unusual behaviour. Identify which further information could change the decision and whether it can be obtained lawfully and proportionately. Incomplete knowledge justifies neither certainty of guilt nor indifference to an actual risk.

For Cyprus apply section 19(1): delete personal data within three months after completion of the procedure. Where the specified judicial or disciplinary proceedings have begun, retain data throughout them, including appeals or objections, and delete after one year has elapsed following their completion. A generic five-year period does not state this rule.

3. Case Study & Compliance Action

A group schedule requires five years from receipt in every country. Now read the case carefully. Separate established facts from information you would still need to confirm. Do not add motives or events that have not been described. This distinction matters when choosing a response proportionate to the information available.

The exercise is as follows: Can it be adopted unchanged? Choose an answer and write one sentence explaining it. During the pause, compare your choice with the criteria we have just considered. Also think about the material you would retain to explain the decision later.

No. Match the schedule to the national rule, exceptions and starting events.

One mistake to avoid is: one period without national examination.

Now apply the national rule to a second decision. The system deletes every case five years after receipt, regardless of country and pending proceedings. Is this suitable?

No. Apply the specific national retention rule and its starting event. Consider pending judicial or disciplinary proceedings where required. Record the decision by category, include copies and designate the person who reviews a suspension of deletion.