Data Retention & Lifecycle Management
1. Purpose & Scope
This policy establishes the standardized framework for the retention, storage, and disposal of all data assets across Aevum Zenth Conglomerate and its 400 subsidiaries. It aligns with global regulatory requirements, internal risk management protocols, and operational continuity standards.
Scope: Applies to all structured and unstructured data, including but not limited to customer records, financial transactions, HR personnel files, IP repositories, communications, system logs, and IoT telemetry. Covers on-premises, cloud, hybrid, and edge storage environments.
2. Data Classification Framework
Retention periods are determined by data sensitivity, regulatory jurisdiction, and business utility. All data must be tagged upon creation or ingestion.
- Level 1 (Public): Marketing assets, press releases, open-source documentation.
- Level 2 (Internal): Operational procedures, internal memos, non-sensitive HR data.
- Level 3 (Confidential): Customer PII, financial records, contracts, proprietary research.
- Level 4 (Restricted): Health data (HIPAA/GDPR), cryptographic keys, defense/aerospace schematics, executive compensation.
3. Standard Retention Schedule
Retention periods are minimums. Jurisdictional laws may mandate longer or shorter windows. Local legal counsel must validate extensions.
| Data Category | Classification | Retention Period | Disposition | Legal Basis |
|---|---|---|---|---|
| Customer Contracts & Agreements | Confidential | 7 years post-termination | Secure archival → Cryptographic wipe | UCC, GDPR Art. 17, SOX |
| Financial & Audit Records | Restricted | 10 years | WORM storage → Certified destruction | SARBOX, SEC, IFRS |
| HR & Employment Files | Confidential | 6 years post-separation | Encrypted vault → Anonymization | FLSA, EEOC, GDPR |
| System & Security Logs | Internal | 1 year (hot) / 3 years (cold) | Rotation → Overwrite | NIST 800-53, ISO 27001 |
| R&D & IP Documentation | Restricted | Perpetual (or patent life) | Immutable backup → Air-gapped archive | Trade Secret Act, WIPO |
| Marketing & Analytics | Internal | 3 years | Deletion → Metadata retention | CCPA, ePrivacy |
4. Storage & Security Standards
All retained data must adhere to the Zenth Data Lifecycle Architecture (ZDLA) v3.1:
- Encryption: AES-256-GCM at rest, TLS 1.3+ in transit. Key rotation every 90 days via Azure Key Vault / AWS KMS.
- Access Control: Role-based (RBAC) with mandatory MFA. Least-privilege enforcement via PAM systems.
- Archival: Tiered storage (SSD → HDD → Tape/Obj). WORM compliance for regulated records.
- Integrity: SHA-256 checksums verified quarterly. Immutable audit trails for all access/modification events.
5. Disposal & Deletion Protocols
Data must be destroyed when retention periods expire or business justification ceases:
- Logical Deletion: Secure overwrite (DoD 5220.22-M / NIST 800-88) for standard storage.
- Cryptographic Erasure: Key destruction for encrypted volumes/cloud objects.
- Physical Destruction: Degaussing, shredding, or incineration for magnetic/optical media. Requires third-party certification.
- Verification: Automated compliance scanners validate disposal completion. Certificates of destruction archived for 5 years.
6. Legal Holds & Exceptions
Retention schedules are automatically suspended when a legal hold is issued by General Counsel or external regulatory bodies. Hold notifications propagate across all systems within 48 hours. Superseding laws or litigation discovery mandates override standard disposal workflows. All holds are logged in the Azure Legal Hold Manager and audited monthly.
7. Compliance & Auditing
The Office of the CISO, in coordination with Internal Audit, conducts semi-annual retention compliance reviews. Automated data mapping tools track lifecycle states across hybrid environments. Non-compliance incidents are escalated to the Risk Committee and may result in corrective action plans or policy revisions.
8. Contact & Amendments
This policy is reviewed annually or upon material regulatory change. Questions, exceptions, or reporting should be directed to:
- Data Governance Team: governance@aevumzenth.internal
- Legal & Compliance: legal-compliance@aevumzenth.internal
- Policy Management Portal: policies.aevumzenth.com/dlp-09