Data Retention and Disposal Policy

Document control

Field	Value
Document status	Active policy document
Owner	Security / Operations / Legal
Approver	Management
Review frequency	Annual or on material change
Classification	Customer-shareable

Purpose

This policy defines how Hybrowlabs retains, archives, returns, deletes, anonymizes, and disposes of company and customer information.

The objective is to ensure information is kept only for legitimate business, legal, contractual, operational, security, or compliance purposes and is securely removed when no longer required.

Scope

This policy applies to information stored or processed in:

• Business applications and internal systems.
• Customer project systems and support tools.
• Databases, file storage, object storage, repositories, and backups.
• Emails, tickets, chat messages, meeting notes, and attachments.
• Laptops, servers, development environments, and temporary workspaces.
• Logs, exports, screenshots, reports, and audit evidence.
• Paper documents and physical media where applicable.

It applies to employees, contractors, vendors, subprocessors, and any personnel who create, access, process, store, export, or delete company or customer information.

Retention principles

Hybrowlabs follows these retention principles:

1. Purpose-based retention

Information must be retained only while it is needed for a valid purpose such as service delivery, support, legal obligation, audit, security, finance, HR administration, or contractual requirement.

2. Minimum necessary retention

Information should not be retained indefinitely unless there is a documented reason. Temporary working files, exports, screenshots, and local copies should be deleted once the work is complete.

3. Secure disposal

Disposal must be appropriate to the sensitivity of the information. Confidential and Restricted information require stronger controls than public or internal information.

4. Traceability

For sensitive or customer-related deletion, evidence should be maintained where contractually or operationally required.

5. Legal and contractual precedence

Legal holds, contractual commitments, regulatory obligations, and customer agreements may override standard retention timelines.

Roles and responsibilities

Role	Responsibilities
Management	Approves retention approach, exceptions, and legal/commercial escalations.
Security / Operations	Maintains retention controls, disposal processes, evidence, and exceptions.
Legal / Commercial Owner	Confirms contractual, legal, and customer-specific retention obligations.
Project / Delivery Owner	Ensures project data is retained or removed according to customer and business requirements.
HR / Admin	Manages retention and disposal of employee, contractor, and applicant records.
Finance / Accounts	Manages retention of invoices, tax records, contracts, and financial documents.
System Owners	Ensure system-specific retention, archival, backup, and deletion controls are implemented.
All Personnel	Delete temporary and unnecessary copies; do not retain sensitive information without business need.

Information categories

Retention expectations depend on the type of information.

Category	Examples	Typical retention basis
Customer project records	Requirements, SOWs, implementation notes, approvals, deliverables	Contractual/business need
Customer data	Data accessed or processed during service delivery	Customer instruction, contract, operational need
Support records	Tickets, issue logs, troubleshooting notes, screenshots	Support auditability and service continuity
Security records	VAPT reports, incident records, access reviews, audit evidence	Security, compliance, contractual need
HR records	Employee files, contractor records, training, BGV status	Employment, legal, compliance need
Finance/legal records	Invoices, contracts, tax records, purchase orders	Legal, tax, finance need
Logs	Application, access, admin, deployment, system logs	Security, troubleshooting, auditability
Temporary files	Local exports, ad-hoc spreadsheets, screenshots, draft files	Short-term work only
Credentials/secrets	API keys, tokens, passwords, certificates	Only while active and required

Retention schedule requirements

Each system or information category should have a defined retention approach where practical.

A retention schedule should include:

• Information category.
• System or storage location.
• Owner.
• Business purpose.
• Classification level.
• Retention period or retention trigger.
• Disposal method.
• Approval requirement.
• Exception or legal hold handling.
• Evidence requirement.

Default retention guidance

The following guidance should be used unless a contract, law, or system-specific policy requires otherwise.

Information type	Retention guidance	Disposal method
Temporary local exports and screenshots	Delete when task is complete, generally as soon as practical	Delete local copies and empty temporary storage where applicable
Draft documents	Retain only until final version is approved or no longer needed	Delete or archive depending on business value
Final project deliverables	Retain for business/contractual reference	Archive or delete according to agreement
Customer-provided files	Retain only for agreed service purpose	Return/delete at exit or when no longer required
Support tickets and notes	Retain for support history and auditability	Archive/delete according to support retention rules
Security evidence	Retain for audit, remediation, and customer assurance	Archive securely; delete when no longer required
Incident records	Retain for investigation, lessons learned, and compliance	Secure archive; restricted access
Access review records	Retain for audit and control evidence	Secure archive
Logs	Retain according to system criticality and storage capability	Automatic expiry or secure deletion
Credentials/secrets	Retain only while active and required	Revoke/rotate/delete securely
HR and finance records	Retain according to legal/business requirements	Secure deletion/destruction after retention period

Customer data retention

Customer data must be retained only for the purpose agreed with the customer or required for service delivery.

Requirements:

• Customer data must not be copied into unmanaged locations without valid need.
• Temporary copies must be deleted after use.
• Customer data must not be retained for unrelated future use.
• Customer exit requirements must be followed at contract completion or termination.
• If customer instructions conflict with legal or security obligations, escalate to management/legal for resolution.

Personal data retention

Personal data must be retained only for a valid business, legal, contractual, HR, finance, support, or security purpose.

Controls:

• Minimize personal data in documents, screenshots, and exports.
• Remove personal data from temporary files when no longer needed.
• Retain HR/finance/legal personal data according to applicable requirements.
• Delete or anonymize personal data when retention is no longer justified.
• Maintain evidence for deletion/return where required.

Temporary files and local copies

Temporary files create unnecessary risk and must be actively controlled.

Examples include:

• Spreadsheet exports.
• Downloaded customer files.
• Debug logs.
• Screenshots.
• Data migration files.
• One-time analysis files.
• Files shared for review.

Rules:

• Store temporary files only in approved locations.
• Do not keep temporary sensitive files on local devices longer than needed.
• Delete temporary working copies after completion.
• Do not upload temporary sensitive files to unapproved tools.
• Do not retain old versions unless they have audit or business value.

Backups and archived data

Backups are maintained for recovery and continuity purposes.

Requirements:

• Backup retention should be documented for critical systems.
• Backups should be access-controlled.
• Backups containing sensitive data should be encrypted where supported.
• Backup restoration should be limited to authorized personnel and approved purposes.
• Data may remain in backups until normal backup expiry unless a specific agreement or legal requirement states otherwise and deletion is technically feasible.

Logs retention

Logs may contain personal data, identifiers, IP addresses, error details, and operational information.

Requirements:

• Logs should be retained based on operational and security need.
• Logs must not intentionally store passwords, API keys, tokens, or secrets.
• Access to logs should be restricted based on need.
• Sensitive logs should not be exported or shared broadly.
• Log retention should balance auditability, troubleshooting, privacy, and storage cost.

Legal holds

A legal hold preserves information that may be relevant to legal, regulatory, contractual, audit, or investigation matters.

When a legal hold applies:

• Normal deletion must be suspended for the affected information.
• Relevant owners must be notified.
• Scope and duration must be documented.
• Access must remain restricted.
• Deletion may resume only after the hold is released by authorized management/legal owner.

Customer exit and project closure

At the end of a customer engagement or project, the project owner should review what information must be retained, returned, archived, or deleted.

Exit checklist:

• Identify customer data and documents in Hybrowlabs-controlled systems.
• Confirm contractual return/deletion requirements.
• Return deliverables or agreed data to the customer where required.
• Revoke project-specific access.
• Delete temporary working files and local copies.
• Archive final contractual/business records where required.
• Update subprocessor/vendor access if applicable.
• Record deletion/return completion evidence where required.

Disposal methods

Disposal method should match information sensitivity.

Information type	Disposal method
Normal digital files	Delete from approved system when no longer required
Confidential digital files	Delete and revoke shared access; confirm removal of temporary copies where practical
Restricted files	Secure deletion, access revocation, deletion evidence, and credential rotation where relevant
Credentials/secrets	Revoke, rotate, invalidate, or delete from secret store/configuration
Physical documents	Shred or securely destroy where sensitive
Devices/media	Wipe, reset, destroy, or return through approved asset-disposal process
Backups	Expire through documented backup retention lifecycle unless otherwise required

Secure deletion expectations

For sensitive information, deletion should include:

• Removing the primary copy.
• Revoking links and shared access.
• Deleting unnecessary local downloads.
• Removing temporary processing files.
• Rotating secrets if exposure is possible.
• Recording completion where required.

Where deletion cannot be fully completed due to backup lifecycle, legal hold, or technical limitation, the limitation must be documented and reviewed.

Disposal of credentials and secrets

Secrets must not be retained beyond their active need.

Requirements:

• Revoke or rotate credentials when no longer needed.
• Remove old keys from configuration and secret stores.
• Disable unused service accounts.
• Rotate credentials exposed through email, chat, tickets, logs, screenshots, or repositories.
• Maintain evidence for high-risk revocation/rotation.

Deletion requests

Deletion requests may come from customers, internal owners, employees, contractors, or legal/compliance requirements.

Process:

1. Validate requester authority.
2. Identify systems and data in scope.
3. Confirm legal/contractual retention obligations.
4. Approve deletion or define exception.
5. Execute deletion/return/anonymization.
6. Revoke access and remove temporary copies.
7. Record completion evidence where required.

Exceptions

Retention or disposal exceptions must be documented.

Exception record should include:

• Information involved.
• Owner.
• Reason for exception.
• Risk.
• Retention extension or disposal delay.
• Compensating controls.
• Approval.
• Expiry/review date.

Examples:

• Extended retention for open dispute or audit.
• Backup lifecycle limitation.
• Legal hold.
• Customer-approved extended support retention.
• Technical limitation preventing immediate deletion.

Incident handling

Retention/disposal failures may create security or privacy risk.

Examples:

• Customer data retained after exit without reason.
• Sensitive exports left on local devices.
• Public shared link not revoked.
• Old credentials not rotated.
• Personal data retained in unapproved tools.

If discovered:

1. Contain access or revoke links.
2. Delete or secure the information.
3. Notify responsible owner/security if sensitive.
4. Rotate exposed credentials where applicable.
5. Record corrective action.
6. Update process controls if needed.

Review and monitoring

Retention and disposal practices should be reviewed periodically.

Review activities may include:

• Checking stale shared folders.
• Reviewing old project workspaces.
• Reviewing access to archived systems.
• Checking local/export cleanup after sensitive tasks.
• Reviewing backup and log retention settings.
• Reviewing open exceptions and legal holds.

Evidence to maintain

• Approved Data Retention and Disposal Policy.
• Retention schedule or retention register.
• Customer exit checklist.
• Deletion/return confirmation.
• Access revocation evidence.
• Backup retention settings.
• Log retention settings.
• Legal hold records.
• Exception register.
• Credential revocation/rotation evidence.
• Disposal records for physical/media assets where applicable.