Legal draft

Retention, deletion and portable export

Purpose-based rules for credentials, evidence, released reports, audit records, backups and exit.

Draft v0.2 · statutory-minimum schedule proposed for counsel approval

Retention principles

  • Keep information only for a documented service, security, contract, dispute or legal-record purpose.
  • Separate short-lived operational records from evidence and released records whose integrity must be preserved.
  • Record the approved period, trigger, owner, access class and deletion method for each category.
  • Use a scoped legal hold with reason, owner and review date rather than a blanket deletion freeze.
  • Never justify indefinite identifiable retention by convenience or model training.

Draft category schedule

Proposed minimum and operational retention schedule
RecordPeriod/triggerExit treatment
Source secretOnly while authorised; disable immediately on revocation and destroy within 30 days unless a documented recovery or legal hold appliesDelete secret; retain non-secret version/revocation audit for seven years
Raw/canonical financial evidence, ledger and journalsSeven years after the end of the relevant financial year, transaction or final release; longer while a SARS audit, objection, appeal, investigation, dispute or scoped legal hold remains openPortable export; restricted immutable retention to expiry, then verified deletion/de-identification
Released report, workpaper, approval and filing handoffSeven years after the relevant financial year or releaseImmutable retention or linked lawful supersession
KYB/KYT/Travel Rule and partner transaction evidenceFive years from the transaction/report or termination of the regulated relationship; seven years where the same item supports a financial/accounting recordPartner remains owner of its regulatory record; ChainClose restricts its orchestration copy to the documented purpose
Contracts, orders, billing, tax invoices and complaintsSeven years after termination, invoice/transaction or final complaint resolutionRestricted archive; no operational reuse
Privileged access and financial-action auditSeven years after the event; longer only for an active incident, dispute or legal holdAppend-only restricted retention
Operational security, request and application logsTwelve months; incident extracts up to seven years where required for defence or accountabilityRolling expiry with identifiers minimised
Workflow history and invitation claim materialTemporal closed history 30 days; invitation claim/secret seven days; delivery evidence seven yearsExpire token/payload automatically; retain non-secret outcome lineage
Support records and unsuccessful sales enquiriesSupport: three years after closure unless attached to a seven-year record; sales enquiry: twelve months after closure; never-paid inactive account: 24 months after last useDelete/de-identify; retain minimum opt-out suppression while required
Operational backupsCloud SQL: 30 daily backups and seven-day PITR; independent logical backups: at least 35 days; immutable evidence objects follow their seven-year record periodEncrypted rolling expiry; verified deletion is reapplied after a restore

Verified deletion

Deletion requires authenticated authority, dependency and legal-hold checks, a logged request, active-system deletion or de-identification, provider propagation and a backup-expiry record. The target is 30 days for active systems and the next applicable rolling-backup expiry, unless law or a recorded hold requires retention. Where information must remain, access is restricted and the purpose, statutory/contractual basis and review date are recorded.

Portable exit

The supported export covers evidence indexes, canonical records, source coverage, policy/classification versions, ledger, reconciliations, journals, workpapers, reports, approvals and audit references in documented formats. It excludes secrets and another tenant's information.

Official sources

External references used for the factual and regulatory context on this page.