← GLBA · Safeguards Rule (16 CFR 314)

314.4(c)(6) — Secure disposal within two years and periodic review of retention

high data-deletiondata-retentionmedia-disposal

Requirement

Customer information is securely disposed of no later than two years after the last date it was used to provide a product or service to the customer, unless it is needed for business operations or other legitimate purposes, required by law, or targeted disposal is infeasible; the data retention policy is reviewed periodically to minimise unnecessary retention.

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
dispos…deletedeleteddeletiondestroy…purge…shred…
Required element 2 — any one of
two years2 years24 monthsretention policyretention scheduleno longer neededlast used
Supporting terms — specificity signals
314.4(c)(6)periodic reviewlegal holdlegitimate business
Contradiction markers

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

retained indefinitely kept indefinitely never deleted

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 CC6.5 Disposal of physical and logical assets media-disposal 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.7.14 Secure disposal or re-use of equipment media-disposal 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
COPPA 312.10 Written data retention policy for children's information data-retention data-deletion