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There is no single retention period that fits every organization or type of identity data. Keep identifiable records only for as long as they serve a defined purpose or an applicable legal, regulatory, contractual, or records-management duty requires. Set a deletion or review trigger for each category, document the reason for any longer retention, and carry the decision through connected systems and service providers.
How long can personal data be kept?
As short a time as the organization can while still meeting the purpose for which it collected the data and any applicable retention duties. The European Commission’s GDPR guidance says personal data should be stored for the shortest time possible. It also says organizations should set time limits to erase or review stored data. That principle applies within the GDPR’s scope; it is not a universal retention schedule for every organization worldwide. See the Commission’s guidance on GDPR principles and storage limitation.
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The right period depends on the organization’s jurisdiction, sector, record type, purpose, and applicable laws and policies. A legal requirement to preserve particular evidence does not automatically justify keeping every identity attribute indefinitely. Define the required record narrowly, retain it only as required, and delete or reduce the rest when its purpose ends.
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Identity data can be spread across enrollment, authentication, security, and connected services. Inventory the records and copies the organization actually holds, then set a purpose and a deletion or review trigger for each category. The examples below are a planning aid, not prescribed periods or legal advice.
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| Record category | What to establish in the retention schedule |
|---|---|
| Identity proofing evidence | Which evidence is necessary to establish or validate the claimed identity, who needs it, and what rule or operational need justifies retaining it after proofing. |
| Account attributes | Which attributes are needed to provide the service or make an authorization decision, and whether they remain necessary after an account closes or a relationship ends. |
| Biometric information | The applicable regional or sector requirements, a documented deletion process, a default retention period, and how subscriber deletion requests will be handled. |
| Authenticators and authentication records | Which records support active access, account recovery, security, or another stated purpose, and the event that ends that need. |
| Fraud, security, audit, or dispute records | The specific purpose and any legal, policy, or records-schedule requirement that supports continued retention; identify the minimum evidence needed for that purpose. |
| Copies held by service providers or relying parties | Who holds each copy, which retention rules apply to that holder, how termination or deletion is communicated, and how completion is verified. |
For each category, record the purpose, users, minimum necessary evidence, applicable retention obligation, and deletion or review trigger. NIST’s identity proofing guidance says processing of personal information should be limited to what is needed to validate and associate the claimed identity, mitigate fraud, and provide attributes that relying parties may use for authorization decisions. The requirement is in NIST SP 800-63A, General Privacy Requirements.
When no law sets a period, make a documented risk-based decision
If there is no mandatory retention period, do not choose an arbitrary number or simply keep records for as long as storage is available. Assess how long the stated purpose genuinely requires the records, the privacy and security risks of retaining them, and the operational consequences of deleting them. Select the shortest period that still meets the purpose, record why it is appropriate, and tell subscribers what the policy is.
NIST SP 800-63B-4, Records Retention Policy, directs a verifier or the relevant credential service provider or identity provider to conduct a risk-management process—including privacy and security risk assessments—to determine how long records should be retained when no mandatory requirement applies, and to inform subscribers of that policy. NIST digital identity guidance can inform this decision, but it does not replace legal analysis of an organization’s other records.
- Check the purpose: would keeping this identifiable record still help deliver the service or meet a stated need?
- Check obligations: does a law, regulation, contract, or records schedule require retention, and what exact record and period does it cover?
- Check risk: what harm could result from unauthorized access, misuse, or a breach while the record remains identifiable?
- Check operational need: what minimum information is genuinely needed for recovery, fraud prevention, audit, or dispute handling?
- Check alternatives: could a less identifying, pseudonymized, anonymized, or aggregated record serve the remaining purpose?
Set deletion and review triggers—and make them work across systems
A retention policy is only useful if it translates into an action. For each record category, specify the event that starts the clock or prompts a review, who is responsible, where copies must be addressed, and how exceptions are authorized. Depending on the record and purpose, a trigger might be completion of a process, the end of a service relationship, account termination, or the end of a documented legal or operational need. These are triggers to assess, not universal deadlines.
- Map the data. Identify the primary system, backups or exports where relevant, service providers, and relying parties that receive or store the identity information.
- Assign the rule. Link each category to its purpose, applicable retention requirement, minimum necessary evidence, and deletion or review trigger.
- Automate or schedule action. Configure deletion or a documented review at the trigger, and assign an owner for cases that cannot be handled automatically.
- Propagate the decision. Send appropriate de-provisioning or deletion instructions to downstream parties and providers, subject to valid retention requirements.
- Record exceptions and completion. Document the rule that prevents deletion, restrict use to that purpose, and keep evidence that the scheduled action or review occurred.
Deletion is not the same as closing an account. An organization may need to terminate access promptly while retaining a narrowly defined record for a valid legal, audit, security, or policy purpose. Keep that retained evidence separate from active account attributes wherever practicable, and do not let an exception become a reason to preserve unrelated identity data.
Handle biometrics and federated accounts separately
Biometric information needs an explicit rule
Biometric information is a distinct, high-sensitivity category. NIST SP 800-63A calls for identity proofing providers to document a deletion process and default retention period consistent with applicable regional and sector rules. It also says providers should support subscriber requests to delete biometric information unless law, regulation, or policy restricts deletion. The applicable rule and any exception should be reflected in the schedule and the deletion process, rather than assumed from the general account policy.
Account termination must reach relying parties
In a federated arrangement, the identity provider and relying parties may hold different records and have different obligations. NIST SP 800-63C says an identity provider should de-provision relying-party accounts after termination, except where a relying party’s retention requirements, policy, or regulation prevent it. It also addresses removal of personal information upon termination under the applicable process. Organizations should therefore coordinate access termination and information removal while accounting for a relying party’s valid retention constraint.
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If an organization has a legitimate reason to retain information for a longer period, reassess whether the full identifiable record is still needed. The European Commission identifies anonymization and pseudonymization as possible safeguards for longer retention for public-interest archiving or research. They are not interchangeable: pseudonymized data may still be linkable to a person, so it should not be treated as anonymous. Use the least identifying form that can meet the continuing purpose, and keep any retained data subject to appropriate safeguards.
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