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Storage limitation (data retention)

Definition

The principle that personal data must be kept in identifiable form for no longer than necessary for the purposes for which it is processed.

Storage limitation turns "keep everything forever" into a governed decision. GDPR Art. 5(1)(e) requires that data be kept in identifiable form only as long as the purpose requires; longer storage is possible for archiving, research or statistics with appropriate safeguards. The LGPD (Arts. 15 and 16) lists when processing ends, such as achieving the purpose, the end of the period or a data subject request, and requires deletion afterwards, except for legal obligations, research, transfer to third parties under the law or exclusive use by the controller once anonymized.

In practice, the principle is implemented through a retention schedule: for each data category, a period, the trigger that starts it, the legal reason and the disposal method. Anonymization can be an alternative to deletion when done properly.

AI raises specific questions: how long prompts and outputs are logged, whether training snapshots keep personal data after source records are deleted, and how vendors handle retention. A support chatbot might keep transcripts for a short service period and then delete or anonymize them.

Where this term is assessed

Assessed in the Data Protection & AI Professional (DPAI), domain 1: Data protection foundations.

Also covered in: Responsible AI Practitioner (RAIP)

Primary sources

  • GDPR Art. 5(1)(e)
  • LGPD Arts. 15-16

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