Retention, archiving and deletion

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 retention plan must specify category, legal rule, starting event, duration and review. In Italy, article 14 of Legislative Decree 24/2023 requires retention for the time necessary to process the report and, in any event, no longer than five years from communication of the final outcome. This is a maximum, not a mandatory minimum. Receipt, closure and communication of outcome are different events. The policy must cover copies and exports.

Apply the following rule: Article 14 requires keeping reports and related documentation for the time necessary to process them and no longer than five years from communication of the final outcome. This is a maximum, not a minimum. Pending litigation does not automatically extend it. Assess any separate legal basis or obligation for documents in other proceedings and record the decision.

2. Practical Implementation & Procedure

Define categories, reference event, necessary duration, review owner and final disposition. Apply the statutory maximum for reporting documentation. Litigation does not automatically authorise extending it: any separate obligations or legal bases for documents used in proceedings require a separate, documented assessment. Include exported copies, restrict access and delete manifestly irrelevant data under the applicable 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

A file reaches an internal review date before the statutory maximum while related litigation is pending. The system proposes deletion. The responsible function assesses necessity and legal bases before deciding, without turning the pending dispute into an automatic extension beyond article 14. 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.

A configured date is not enough. Check the Italian rule, the event used in the calculation and actual necessity. Do not automatically retain the file beyond five years from communication of the final outcome. Assess any obligations concerning documents of other proceedings separately and record their basis. Include copies, attachments and access.

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.