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Records Retention Policy

Defines retention periods, legal holds, and disposal requirements for company records by category.

PrivacyIn review

Current version · v2.1

Effective 6/30/2024 — approved by CEO

Records Retention Policy

1. Purpose

This records retention policy establishes the requirements, responsibilities, and expectations governing how AC5 Labs Demo Co protects information assets, manages risk, and meets its contractual and regulatory obligations. It applies to all employees, contractors, interns, and third parties acting on behalf of the company.

2. Scope

This policy covers all information systems, devices, networks, facilities, and data — whether owned, leased, or operated under contract — that are used to conduct company business. It applies regardless of location and includes remote work, customer environments, and bring-your-own-device arrangements.

3. Roles & Responsibilities

The General Counsel owns this policy and is accountable for its content, approval cycle, and exceptions. Department heads are responsible for operationalizing the policy within their teams and ensuring relevant personnel attest within thirty (30) days of hire and annually thereafter.

4. Policy Statements

4.1 The company shall maintain documented controls aligned with the cross-referenced framework requirements listed at the end of this policy.

4.2 Exceptions to this policy must be requested in writing, justified by a documented business need, time-bound, and approved by the policy owner. All approved exceptions shall be logged and reviewed at least annually.

4.3 Violations of this policy may result in disciplinary action up to and including termination of employment or contract, and where applicable, civil or criminal penalties.

5. Compliance & Enforcement

Compliance is verified through periodic internal audits, automated control testing where feasible, and external assessment as part of the company's overall compliance program. Non-conformities will be tracked through the corrective action process and reported to executive leadership monthly.

6. Review

This policy is reviewed at least annually, or sooner if material changes occur in the business, technology environment, or applicable regulations. The reviewer captures changes in the version history and re-attestation is required when a substantive update is published.

Document control: POL-PR-002 v2.1 · Approved per the version history below.

Version history

2 versions on record

  1. v2.1current
    6/30/2024

    Added crypto-shredding option for retired SaaS data.

    Approved by CEO

  2. v2.0obsolete
    6/15/2023

    Major rewrite to consolidate fragmented retention schedules.

    Approved by CEO

Status
In review
Version
v2.1
Effective
6/30/2024
Next review
6/30/2025
Past due

Attestation status

Completed9/11 (82%)

Cross-references

Related framework controls

ISO 27001 A.5.33SOX §802GDPR Art. 5(1)(e)

Distribution list

Owner: General Counsel

  • Legal
    Last reminded 2/20/2026
    3
  • Finance
    Last reminded 2/20/2026
    9
  • IT operations
    Last reminded 2/20/2026
    12