MAINSYSTEMS 
apply retention criteria without confusing closure with erasure
1. Regulatory Concept & Core Standards
This video focuses on how to apply retention criteria without confusing closure with erasure. 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. A reporting case may contain data about the reporting person, people concerned and third parties. Data protection must accompany the whole lifecycle, from the form to archiving. This course addresses operational decisions. Legal bases and restrictions on rights require assessment of the specific processing. The Hungarian section 26 requirements apply alongside GDPR. The Commissioner’s five-year rule is not a universal internal-channel period.
The Act sets no universal five-year employer internal-file period. Section 12’s five years concerns the Commissioner’s protected electronic public-interest system. Internal cases require section 26 and GDPR purpose, necessity and applicable specific obligations. Pending litigation is not a blanket extension or permission to retain all data.
Apply the following rule: Section 26 limits internal-system personal data to what is indispensable for investigation and remediation. Data outside that scope must be deleted without delay. The five years in section 12 concerns the Commissioner’s protected electronic public-interest system, running from completion of the last investigative act or measure, followed by deletion. It is not a universal employer internal-system retention period. Document the specific purpose, lawful basis and review event.
2. Practical Implementation & Procedure
Define information classes, the reference event, duration, review owner and final disposition. Before a scheduled deletion, check the applicable rule, necessity and any pending proceedings. Preserve material only where legally permitted or required; do not invent an extension to a statutory maximum. Include exported copies and archival media, with restricted access. Clearly irrelevant data follow their own deletion rule. 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.
3. Case Study & Compliance Action
An internal review date arrives while litigation is pending. The team identifies the data still needed and the specific lawful basis. It does not keep everything automatically or copy the five-year period belonging to the Commissioner’s protected electronic public-interest system. 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: Does reaching the originally planned date permit automatic deletion of everything? 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. Identify whether the date is an internal review point or a legal limit, then assess the specific preservation and erasure obligations. Litigation is not an unlimited extension. Document the decision for each category, including copies and attachments.
One mistake to avoid is: configuring a single deletion period without legally relevant exceptions.
Now apply the national rule to a second decision. The system deletes every case five years after receipt, regardless of the country and any pending proceedings. Is that appropriate?
No. Identify the local rule, starting event and any limits or extensions. A uniform schedule may delete records too early or retain them too long. Document the decision by category, include copies and define who reviews a suspension of deletion, rather than keeping everything indefinitely.