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INTRA/DP/DP012Retention and disposal of program records

The period for which the program keeps what it produced rather than what it observed: the alert, the case file, the note, the export, the assessment. Distinct from the retention of the business records the program reads, which the organization sets for its own reasons and the program does not control.

Pillar
DP  |  Data and asset protection
Sources cited
15
Added
30 AUGUST 2026
Updated
5 OCTOBER 2026
ControlJurisdictionSourceWhat it establishesPrerequisite or recommendation
DP012/HRMandatoryCroatiaZakon o provedbi Opće uredbe o zaštiti podataka, članci 25 to 30Hrvatski sabor · read 5 Oct 2026That video surveillance serves only a purpose necessary and justified for the protection of persons and property, that the premises are marked before the perimeter is entered with the controller’s identity and contact for rights, that access to footage is limited to the responsible person and those authorized, that an automated log records the time, place, and person of every access to footage, that recordings are kept at most six months unless a law provides longer or they are evidence in proceedings, and that employees are processed by video surveillance only where the occupational safety conditions are met too, the employees were informed beforehand in an appropriate way and before the decision to install, and never in rooms for rest, personal hygiene, and changing.Video surveillance recordings are kept at most six months, unless another law sets a longer period or they are evidence in judicial, administrative, arbitration, or equivalent proceedings.
DP012/LUMandatoryLuxembourgDélibération n° 11FR/2021Commission nationale pour la protection des données, formation restreinte · read 5 Oct 2026Lignes directrices en matière de géolocalisation des véhicules mis à la disposition des salariésCommission nationale pour la protection des données · read 5 Oct 2026That location data kept two years and four months for geographic tracking, protection of goods, and working time of travelling employees exceeded what the purposes needed, that a retention set per purpose is owed, two months for location, one year for billing evidence, three years for working time, that the employees were not informed as article 13 requires, and that access to the geolocation software through shared accounts breached article 32, individual accounts being owed only to those for whom access is strictly necessary to their tasks.Location data are kept two months at most; where the system is the only means of checking working time, three years (five in the public sector); where used as billing evidence, the necessary data one year. Location data kept two years and four months for tracking, protection of goods, and working time exceeded the purposes; the retention is set per purpose, two months, one year for billing, three years for working time.
DP012/NOMandatoryNorwayForskrift om arbeidsgivers innsyn i e-postkasse og annet elektronisk lagret materialeArbeids- og inkluderingsdepartementet · read 29 Aug 2026When an employer may look into a work mailbox or a worker’s personal areas on its equipment, that monitoring of internet use is outside what it may do at all, and that the regulation cannot be contracted around.What is opened and proves not to be necessary or relevant to the purpose is closed at once, and any copy of it deleted.
DP012/PLMandatoryPolandKodeks pracy, article 22(2)Sejm of the Republic of Poland · read 20 Sep 2026That image recording at work is open for four purposes only, one of them keeping secret information whose disclosure could harm the employer, that its purposes, scope and manner are fixed in the collective agreement, the work regulations or an announcement, that it is notified two weeks before it starts and handed to each worker before they are admitted to work, and that recordings are kept three months.Image recordings are processed only for the purposes for which they were collected and kept no longer than three months from the day of recording. After that period those containing personal data are destroyed, unless separate provisions say otherwise.
DP012/PTMandatoryPortugalCódigo do Trabalho, articles 17, 20, 21, 22, and 170-AAssembleia da República · read 5 Oct 2026Deliberação n.º 1638/2013, Princípios aplicáveis aos tratamentos de dados pessoais decorrentes do controlo da utilização para fins privados das tecnologias de informação e comunicação no contexto laboralComissão Nacional de Proteção de Dados · read 5 Oct 2026That remote surveillance to control the worker’s professional performance is prohibited, that it is lawful for the protection and security of persons and goods or where particular requirements of the activity justify it, that the worker is informed of its existence and purpose, that its use is subject to authorization by the CNPD on a request accompanied by the opinion of the comissão de trabalhadores, that the notice reads “Este local encontra-se sob vigilância de um circuito fechado de televisão”, that the data are kept only for the period the purpose needs and destroyed on the worker’s transfer or on termination, that the worker has the right to confidentiality of personal messages and non-professional information sent, received, or consulted, the employer’s power to set rules of use notwithstanding, and that in telework the employer may not capture image, sound, writing, or history, nor impose permanent connection by image or sound.Data from the control of private use of ICT are kept at most six months, save during a disciplinary or judicial proceeding; the logs of access to the monitoring system are kept one year. Remote surveillance data are kept for the period the purpose needs and destroyed on transfer or termination; breach of the retention rule is a contraordenação grave.
DP012/ROMandatoryRomaniaLegea nr. 190/2018, articolul 5Parlamentul României · read 5 Oct 2026Legea nr. 361/2022 privind protecția avertizorilor în interes public, articolele 7, 9, 10, și 36Parlamentul României · read 5 Oct 2026That monitoring by electronic communications or video surveillance at the workplace on the employer’s legitimate interest is lawful only on five cumulative conditions, among them prior consultation of the union or the employee representatives, prior complete and explicit information of the employees, proof that less intrusive means have failed, and a retention of no more than 30 days.Data from workplace monitoring by electronic communications or video surveillance are kept no longer than 30 days, save where the law expressly provides otherwise or a case is duly justified. Reports received through the internal channel are entered in an electronic register and kept for 5 years, then destroyed whatever the medium.
DP012/SEMandatorySwedenLag (2021:890) om skydd för personer som rapporterar om missförhållandenRiksdag · read 5 Oct 2026That an operator with 50 or more workers at the start of the calendar year has internal reporting channels, run by independent and autonomous persons or units, that receipt is confirmed within seven days and feedback given within three months, that oral reports are documented and documentation kept no longer than two years after the follow-up case is closed, and that whoever handles a report may not disclose what reveals the reporter’s identity.Oral reports are documented by recording or minutes, and written reports and documentation are kept no longer than two years after the follow-up case is closed.
DP012/GBMandatoryUnited KingdomData Protection Act 2018, section 10 and Schedule 1Parliament of the United Kingdom · read 30 Aug 2026The condition on which an employer may process a closed category at all, and the document that condition requires to exist before the processing starts.The appropriate policy document has to explain the policies on retention and erasure of the data processed under the condition, and to give an indication of how long they are likely to be kept. An indication is what is asked for, not a period.
RecommendedAustriawhere writtenÖsterreichisches Informationssicherheitshandbuch 4.4.0Bundeskanzleramt und A-SIT · read 29 Aug 2026That logging is only effective as a security measure once someone independent reads it, that where nobody independent can, the administrators’ own activity is what stops being checkable, and that the evaluation goes before the Data Protection Officer either way.Log files hold personal data in many cases, so they may be used only for purposes compatible with the one they were collected for. Where that restriction bites, the handbook says it is resolved by removing the personal data or by anonymizing them, and states that pseudonymizing them is not enough.
RecommendedNorwaywhere writtenNSMs grunnprinsipper for IKT-sikkerhet 2.1Nasjonal sikkerhetsmyndighet · read 29 Aug 2026A set of principles for securing information systems, with the monitoring ones carrying what the collected data may be used for, what employees are to be told about it, and the requirement to verify that the collection is working.The security relevant data are to be used only to safeguard the security of the systems, and kept long enough that unwanted activity can be discovered and mapped after the fact. What weighs on the period is that the data may later be wanted for an investigation, for assessing damage, and for trend analysis, held against the point that they can hold confidential information about the individual employee.
RecommendedUnited Kingdomwhere writtenEmployment practices and data protection: monitoring workersInformation Commissioner's Office · read 30 Aug 2026What the British regulator expects of an employer that watches its workers, told apart as what an employer must do and what it should, and the conditions it sets on watching them without telling them.What monitoring produces must not be kept longer than is necessary for the purpose. The period should rest on business need and be reviewed regularly, and it should not be kept in case a purpose is found for it later. A retention schedule must exist and what is collected must be deleted in line with it.