← COPPA · Security and retention

312.10 — Written data retention policy for children's information

high data-retentiondata-deletionchildren

Requirement

Children's personal information is retained only as long as reasonably necessary for the specific purpose it was collected for, never indefinitely; the operator maintains a written data retention policy stating the purposes, the business need, and the timeframe for deletion, publishes it in its online notice, and deletes the information securely.

What the engine looks for

Every group below must be satisfied — by an affirmative statement, not a plan, a hedge or a denial — for the control to count as covered. A term ending in … matches any word it begins. Supporting terms do not change the verdict — they raise confidence and distinguish a policy that names a mechanism from one that gestures at a category.

Required element 1 — any one of
childrenchildkidsunder 13under the age of 13under-13minorschildren's datachildren's personal informationchild's data
Required element 2 — any one of
retention policyretentionretain…deletedeleteddeletion
Required element 3 — any one of
reasonably necessarytimeframedaysmonthswrittennot indefinitelyspecific purpose
Supporting terms — specificity signals
312.10online noticesecurely delete
Contradiction markers

Finding any of these outranks coverage — a policy that admits the gap is worse than silence.

retained indefinitely kept indefinitely stored indefinitely

Equivalent controls elsewhere

Matched on shared topics. Satisfying this control usually moves these too.

FrameworkControlTitleShared topics
GDPR Art.5(1)(e) Storage limitation data-retention data-deletion
SOC 2 C1.2 Disposal of confidential information data-deletion data-retention
SOC 2 P4.1 Use, retention and disposal of personal information (P4.1–P4.3) data-retention data-deletion
ISO 27001 A.8.10 Information deletion data-deletion data-retention
PCI DSS 4.0.1 3.2 Minimise storage of account data data-retention data-deletion
GLBA 314.4(c)(6) Secure disposal within two years and periodic review of retention data-deletion data-retention
GDPR Art.8 Conditions for a child's consent to online services children
GDPR Art.17 Right to erasure (“right to be forgotten”) data-deletion