An organization is implementing a data retention policy for personally identifiable information (PII) to comply with GDPR. Which of the following is the MOST appropriate approach?
GDPR mandates that data be kept no longer than necessary; defined retention periods with secure deletion ensure compliance.
Why this answer
GDPR mandates that PII must not be kept longer than necessary for the purpose for which it was collected. Defining retention periods based on legal and business requirements ensures compliance with the storage limitation principle (Article 5(1)(e)), and secure deletion (e.g., using cryptographic erasure or overwriting with tools like shred on Linux) prevents unauthorized recovery. This approach balances regulatory compliance with operational needs.
Exam trap
The trap here is that candidates may confuse 'anonymization' (Option B) as a safe harbor for indefinite retention, but GDPR requires that anonymization be irreversible and that the retained data serve a legitimate purpose, not just be kept indefinitely without justification.
How to eliminate wrong answers
Option A is wrong because deleting PII immediately upon collection would violate legitimate business and legal requirements (e.g., tax records or contractual obligations) that necessitate retention for a defined period. Option B is wrong because anonymization after a fixed period may comply with GDPR if irreversible, but retaining anonymized data indefinitely still poses re-identification risks (e.g., via linkage attacks) and violates the principle of data minimization if no business need exists. Option C is wrong because retaining PII indefinitely for historical analysis violates GDPR's storage limitation principle unless the data is anonymized and the purpose is compatible with the original collection; indefinite retention of PII without a legal basis exposes the organization to fines and breach risks.