Under the CCPA and CPRA, businesses are required to disclose how long personal information is retained or the criteria used to determine retention periods. The law does not mandate fixed retention timelines, but it limits retention to what is reasonably necessary for disclosed purposes and prohibits keeping personal information indefinitely without justification. This guide explains how CCPA data retention rules work, what regulators expect businesses to disclose, how retention ties into data minimization and purpose limitation, and why retention practices are increasingly scrutinized in enforcement actions.
CCPA Data Retention Rules: What Businesses Must Disclose
Introduction: why data retention matters under the CCPA
Data retention sits at the intersection of transparency, data minimization, and accountability under the California Consumer Privacy Act (CCPA). While the law does not prescribe exact retention timelines, it requires businesses to think deliberately about how long personal information is kept and to explain those decisions to consumers.
In practice, retention issues often surface during enforcement reviews when businesses cannot explain why personal information is still stored years after its original purpose has expired. Retention disclosures that are vague, outdated, or disconnected from actual practices are a recurring regulatory concern.
This article explains what the CCPA requires with respect to data retention, how retention periods must be disclosed, how retention ties into broader privacy principles, and how businesses can reduce risk by aligning disclosures with operational reality. These obligations connect closely with other CCPA notice requirements, including the notice at collection that informs users upfront about retention, the Do Not Sell or Share requirements that affect downstream use of data, and the disclosures documented in a business’s CCPA privacy policy.
Does the CCPA set specific data retention periods?
No. The CCPA does not impose fixed retention timelines such as “three years” or “seven years” for personal information.
Instead, California Civil Code section 1798.100(a)(3) requires businesses to disclose how long each category of personal information is retained, or the criteria used to determine that period. Retention must be limited to what is reasonably necessary for the purposes disclosed at the time of collection.
This means retention decisions depend on context, including the type of data collected, the purpose of collection, and applicable legal or operational obligations. Businesses that rely on generic timelines without linking them to purpose often struggle to justify retention during reviews.
Common misconceptions about “standard” CCPA retention periods
Search queries frequently reference concepts such as a “7-year retention policy” or fixed multi-year rules. These concepts often come from accounting, tax, or employment laws, not from the CCPA itself.
Under the CCPA:
- There is no universal 7-year retention rule
- Retention periods vary by data category and purpose
- Different legal obligations may apply to different records
Retention requirements under other laws may justify keeping certain records longer, but those obligations do not override the CCPA’s requirement to explain and justify retention to consumers.
How CCPA data retention ties into purpose limitation and data minimization
Retention rules under the CCPA are closely connected to the principles of purpose limitation and data minimization.
Personal information should not be retained longer than necessary to fulfill the purposes disclosed at collection. When a purpose expires, continued retention must be justified by a new, lawful basis such as legal obligations or ongoing consumer relationships.
Regulators often evaluate whether retention practices align with stated purposes, not just whether a disclosure exists. A retention statement that allows data to be kept “as long as necessary” without explanation is commonly viewed as insufficient.
What must be disclosed about data retention under the CCPA
Under the CPRA amendments, businesses must disclose:
- Retention periods for each category of personal information, or
- The criteria used to determine how long each category is retained
These disclosures typically appear in the privacy policy and may also be referenced in notices at collection. They must reflect actual retention practices, not aspirational policies.
For an overview of how retention disclosures fit into the broader notice framework, see our guide on CCPA notices and disclosures.
Where must data retention disclosures appear under the CCPA
In practice, retention information is commonly disclosed in:
- The privacy policy
- Sections addressing specific data categories
- Tables summarizing categories, purposes, and retention criteria
These disclosures should align with other statements about data use and consumer rights. Inconsistencies between retention disclosures and actual deletion practices are frequently cited during enforcement reviews.
How does data retention affect consumer rights requests
Retention practices also affect how businesses respond to consumer rights requests.
For example, when handling data subject requests, businesses should not retain personal information longer than necessary solely to process a request. Verification steps and request logs must themselves follow data minimization principles.
Retention tied to request handling is an area where regulators increasingly look for proportionality and purpose alignment.
Common retention-related compliance challenges
Businesses often face similar challenges when managing retention, including:
- Retention schedules that are not documented clearly
- Disclosures that are too vague to be meaningful
- Different systems applying different retention logic
- Difficulty aligning legacy data with updated purposes
These challenges are amplified for organizations operating across multiple domains, regions, or data systems.
How Clym supports data retention transparency
Once businesses understand their retention obligations, the next challenge is keeping retention disclosures aligned with how data is actually handled across their domains.
Clym supports retention transparency by helping businesses manage and publish retention-related disclosures as part of their privacy policy through the Clym Control Center. Businesses can either add an existing privacy policy or generate one by completing a guided questionnaire, then document retention information alongside the rest of their policy content as data practices evolve.
Once added, the privacy policy and its retention disclosures can be displayed consistently across a website, rather than being manually copied into individual pages. This helps keep retention statements aligned across domains and allows them to be referenced from notices at collection or other disclosure points.
For more details, check our guide on how to create a CCPA privacy policy.
Frequently asked questions about CCPA data retention
The CCPA requires businesses to limit retention to what is reasonably necessary for disclosed purposes and to explain how long personal information is kept or how retention periods are determined. The law does not set fixed timelines.
The CCPA does not include a 7-year retention requirement. References to seven-year retention usually come from other legal or accounting obligations and must be evaluated separately from CCPA disclosure requirements.
The CCPA requires disclosure of retention periods or criteria, typically through a privacy policy. While many businesses document retention internally, the legal obligation focuses on transparency to consumers.
No. Retention must be tied to disclosed purposes and limited to what is reasonably necessary. Indefinite retention without justification is inconsistent with CCPA principles and commonly scrutinized in enforcement actions.
The CCPA does not define what is “reasonable” using specific timeframes. Instead, reasonableness depends on the purpose for which the personal information was collected, the nature of the data, and any applicable legal or operational obligations. Regulators assess whether retention periods are logically connected to disclosed purposes rather than whether a specific number of years is used.
Retention periods or retention criteria must be disclosed to consumers, most commonly through the privacy policy. These disclosures may also be referenced in notices at collection when personal information is first collected, particularly where retention information is relevant to the consumer’s decision to proceed.
Retention information is not always required to be displayed in full at the notice at collection, but the CCPA requires that consumers be informed at or before collection about key aspects of data use. In practice, notices at collection often summarize retention criteria or link to the privacy policy where detailed retention disclosures are provided.
Alex is a Content Developer at Clym, where he researches and writes about everything related to data privacy and web accessibility compliance for businesses, helping them stay informed on their compliance needs and spreading awareness about making the web safer and more inclusive. When he’s not writing about compliance, Alex has his nose in a book or is hiking in the great outdoors.
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