AI Log Retention Policy
Define how long AI decision logs, audit trails, and system logs are retained, in what format, and the procedures for their eventual deletion.
Objective
Ensure AI logs are retained long enough to satisfy regulatory requirements and accountability needs, then deleted in compliance with data minimization obligations.
Maturity Levels
Initial
No retention policy exists; logs are deleted based on storage constraints.
Developing
Informal retention periods exist but are not documented or consistently applied.
Defined
A written policy specifies retention periods by log type and system risk tier, tied to regulatory requirements.
Managed
Retention compliance is monitored; deletion procedures are executed and documented.
Optimizing
Retention periods are reviewed annually against evolving regulatory requirements; automated enforcement reduces compliance risk.
Evidence Requirements
What an auditor or assessor would expect to see for this control.
- —Written retention policy specifying periods by log type and risk tier, approved by Compliance and Legal
- —Regulatory requirement mapping justifying each defined retention period
- —Automated deletion workflow configuration confirming TTL enforcement is active and tested
- —Annual retention policy review records with DPO and Compliance sign-off
- —Legal hold process documentation and evidence of deletion suspension for any logs under active hold
Implementation Notes
Key steps
- Map retention requirements by regulation: EU AI Act requires providers of high-risk AI to retain logs for at least 10 years in some cases; GDPR data minimization pulls in the opposite direction — document the tension and your resolution.
- Define separate retention periods for operational logs (shorter), decision records (medium), and high-risk AI audit trails (longest).
- Implement automated deletion workflows — relying on manual deletion creates both compliance risk and litigation hold conflicts.
- Ensure retention policy is aligned with your legal hold procedures to avoid accidental deletion during litigation.
Example Implementation
Mid-size enterprise with AI systems across HR, finance, and customer service
AI Log Retention Policy
| Log Type | Systems | Retention Period | Basis | Deletion Method |
|---|---|---|---|---|
| High-risk AI decision records | HR screening, credit scoring | 7 years from decision | Regulatory requirement | Automated + compliance sign-off |
| Operational AI logs (non-PII) | All systems | 2 years | Internal policy | Automated TTL |
| PII-containing AI logs | Customer-facing systems | 90 days (or shorter per GDPR erasure request) | GDPR data minimization | Automated + DPO sign-off |
| Incident-related logs | Any system involved in incident | Duration of investigation + 3 years | Legal hold | Manual, Legal sign-off required |
| Model evaluation and test logs | All systems | Life of model + 3 years | Audit support | Automated post-deprecation |
Legal hold process: Any log subject to litigation hold is flagged in the log management system; automated deletion is suspended until hold is released by Legal
Annual review: DPO and Compliance review retention periods each January against updated regulatory requirements
Control Details
- Control ID
- ALC-003
- Domain
- Audit & Logging
- Typical owner
- Compliance / Legal / IT
- Implementation effort
- Low effort
- Agent-relevant
- No