Data Retention
Understanding data retention is important for compliance. This guide explains how SAR Portal manages data throughout its lifecycle.
30 days after a case closes, its documents and the requester’s contact details are removed automatically, unless the case is on legal hold. You choose how long the case record itself is kept before it is deleted.
Retention Overview
| Data Type | Active Period | After Closure | Retention Period |
|---|---|---|---|
| Case Data | While open | Requester’s contact details removed 30 days after closure (unless on legal hold) | Closed case record deleted after the retention period you choose, counted from the date the case was created (default 12 months). Open cases and cases on legal hold are never deleted automatically |
| Documents | While the case is open | Kept for 30 days after closure, then deleted when the case is anonymised (unless on legal hold) | None after that |
| Audit Logs | Always | Kept; the requester’s details are removed when the case is anonymised | 7 years, or indefinitely while the case is on legal hold |
| User Data | While active | On request | Until deletion |
Case Data Retention
Active Cases
While a case is open:
- Full personal data stored
- All documents accessible
- Complete editing capability
- Audit trail building
Closed Cases
When a case is closed:
- Status becomes final
- Documents stay available for 30 days, then are deleted (unless the case is on legal hold)
Anonymization
30 days after closure (unless the case is on legal hold):
- Subject name removed
- Email converted to a one-way hash
- Phone number removed
- Case notes cleared
- All documents deleted
- Audit trail preserved
Imported past cases are anonymised 30 days after they were imported.
An Admin can also anonymise a closed case at any time before the 30 days are up: on the case page, click Manual Anonymization in the Case Closure Information panel. This is recorded in the audit log as ManualCaseAnonymization. See Case Actions.
Why Hash the Email?
The email hash allows:
- Future compliance verification
- Matching without storing the email in clear text
- Proving the request was handled
A hash is pseudonymised data, so it is still personal data under GDPR. Anyone who knows the email address can match it, which is how the verification works.
Document Retention
During Active Cases
- Full access to all documents
- Can upload, view, download, delete
- AI processing available
- Redacted versions created
Document Deletion
When documents are deleted:
Soft Delete (Immediate)
- Marked as deleted
- Archived to secure location
- Can be restored while the case is open
- Audit entry created
Permanent Delete (30 Days After Case Closure)
- Physically removed
- Not recoverable
- Storage freed
After Case Closure
30 days after a case closes, all its documents are permanently deleted (unless the case is on legal hold):
- Original files removed
- Redacted versions removed
- Blobs deleted from storage
- Cannot be recovered
Download anything you must keep before then.
This aligns with data minimization principles - don’t keep data longer than necessary.
Audit Log Retention
Standard Retention: 7 Years
Based on:
- GDPR Article 17(3)(e) - legal claims defense
- Typical statute of limitations
- Regulatory guidance
What’s Retained
- All event entries
- Timestamps
- User identifiers
- Action descriptions
Audit logs keep your staff’s names and emails. When a user’s account is erased through account deletion, their email in the audit entries becomes [Redacted].
While a case is on legal hold, its audit entries are kept indefinitely. When the hold is released, they return to normal expiry.
What’s NOT Retained
- Document contents
User Data Retention
Active Users
Full account data retained:
- Name and email
- Role and permissions
- Activity history
- Preferences
Removing a User
There is no deactivate option. An Admin clicks Delete next to the user on the Users page. This removes the user’s sign-in from Microsoft Entra ID and marks the user record as deleted. Their audit entries are not changed. See User Management.
User Deletion (Erasure)
When a user deletes their own account through account deletion:
- Account fully removed
- In audit entries the user performed or that concern them, their email becomes [Redacted] and any IP address becomes ***
- An Audit Logs Pseudonymized - User Erasure entry records the change
- Historical actions are preserved
Tenant/Organization Retention
Active Organizations
All data retained:
- Cases and documents
- User accounts
- Settings and configuration
- Billing information
Organization Deletion
When the last admin deletes the organization, everything runs immediately and synchronously - there is no deferred purge window.
If any case is on legal hold, nothing is deleted and the admin sees: “A case in your organisation is on legal hold, so your organisation’s data cannot be deleted. Nothing has been deleted. Release the legal hold first, or contact support.”
-
Immediate (at deletion)
- Stripe subscription cancelled
- All cases deleted (not anonymized)
- All documents and blobs deleted from storage
- All user accounts removed
- The tenant record removed
-
Retained afterwards
- Anonymized audit logs (7 years, GDPR Article 17(3)(e))
- Billing records (legal requirement)
Configuring Retention
Case Anonymization Timing
Closed cases are anonymised 30 days after closure. You cannot change this period in Settings. An Admin can anonymise a closed case sooner with Manual Anonymization.
Case Retention Period
You choose how long a case record is kept, counted from the date the case was created, before it is deleted (1 to 120 months, default 12). Set it in Settings > Case Management: in the Global Case Retention Period card, enter the Retention Period (Months). You can override it for a single case. Only closed cases are deleted; an open case is never deleted automatically, and cases on legal hold are excluded. See Case Management settings.
Legal Hold
For cases under legal hold:
- Anonymization suspended
- Documents preserved
- Automatic deletion paused
- Audit entries kept indefinitely
- Organization deletion refused
- Until hold removed
See Legal Hold.
Data Minimization
SAR Portal follows data minimization principles:
Collect Only What’s Needed
- Minimum required fields
- Optional fields clearly marked
- No unnecessary data collection
Store Only While Needed
- Active cases: full data
- Closed cases: anonymised 30 days after closure (unless on legal hold)
- Documents: deleted 30 days after closure (unless on legal hold)
Delete When No Longer Needed
- Automatic anonymization
- Document purging
- User deletion support
Compliance Evidence
For each case you can export a PDF with its status history and key audit entries (status and date changes, extensions, legal holds, closure). The Audit Logs page exports entries as CSV.
Your Responsibilities
As the data controller, you should:
-
Inform Data Subjects
- Include retention periods in privacy notice
- Explain anonymization vs deletion
- Describe audit log retention
-
Configure Appropriately
- Set retention periods matching your policy
- Enable legal holds when needed
- Review settings periodically
-
Honor Deletion Requests
- Process account deletions promptly
- Understand what can/cannot be deleted
- Explain retained audit logs
Legal Basis for Retention
Audit log retention is based on:
- GDPR Article 17(3)(e): Exemption from erasure for “establishment, exercise or defence of legal claims”
- Legitimate Interest: Defending against future complaints
- Legal Obligation: Various record-keeping requirements
This is documented in our DPA and privacy notice.