Artificial Intelligence (AI) Data Protection and Retention Policy

The purpose of this policy is to ensure the protection of data used, processed, and generated by Artificial Intelligence (AI) systems within the organization.

SecureXcel/AIMS/AI-002Policy1,248 words 6 min readOwner: GRC & Compliance Team
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Published as written. This is SecureXcel's own working document, shown with its document control and notices as they appear in the file. Adapt it to your organization, approve it through your own document control, and treat it as a starting point: it is not legal advice and does not make an organization compliant or certified.

Document control

​Document ID: 002

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​Author(s): GRC Team

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​Version: 1.1

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​Date: 13/07/2026

​Disclaimer:

This controlled document is intended for authorized SecureXcel use. It may not be reproduced, distributed, quoted, or disclosed outside its approved audience without prior authorization from the document owner.

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Document Details

Document TitleArtificial Intelligence (AI) Data Protection and Retention Policy
Document IdSecureXcel/AIMS/AI-002Current Version1.0Date of Release09-Nov-2026
ClassificationInternalAuthorGRC & Compliance Team
Reviewed byGRC & Compliance Lead
Approved byManagement RepresentativeAI Governance Committee (AIGC)
Designation

Revision History

VersionDateAuthorGRC & Compliance TeamGRC & Compliance LeadManagement Representative
1.022/07/2025GRC LeadGRC HeadAIGCInitial version
1.113/07/2026GRC LeadGRC HeadAIGCUpdated section 11

1. Introduction

The purpose of this policy is to ensure the protection of data used, processed, and generated by Artificial Intelligence (AI) systems within the organization. This policy establishes guidelines for securing AI-related data, ensuring compliance with ISO 42001:2023 and relevant data protection regulations such as GDPR.

2. Scope

Artificial Intelligence (AI) Data Protection and Retention Policy

  • All AI models, algorithms, and automated decision-making systems.
  • All employees, contractors, and third-party vendors handling AI data.
  • AI-related data collection, processing, storage, and sharing.
  • Personally Identifiable Information (PII) and sensitive business data processed by AI tools.

3. AI Data Protection Principles

The organization shall adhere to the following AI data protection principles:

  • Data Minimization – Only necessary data will be collected and processed by AI systems.
  • Fairness & Transparency – AI data usage must be clear, explainable, and accountable.
  • Security & Integrity – AI data must be protected against unauthorized access and breaches.
  • Legal Compliance – AI data practices must comply with ISO 42001:2023, GDPR, and other regulations.
  • Accountability & Governance – AI data handling must follow approved governance policies.

4. AI Data Classification and Handling

AI data shall be classified based on sensitivity and handled accordingly:

  • Public Data – Freely accessible, no restrictions on use.
  • Internal Data – Restricted to organizational use, not for public sharing.
  • Confidential Data – Sensitive business or AI training data with controlled access.
  • Personal Data – Includes PII, subject to strict protection and regulatory compliance.

5. AI Data Collection and Consent

To ensure ethical AI data collection:

  • User consent must be obtained before processing personal data.
  • AI systems must not collect excessive or irrelevant data.
  • Individuals must be informed about AI-driven data processing practices.
  • Data collected for AI training must be anonymized where possible.

6. AI Data Storage and Security Measures

To secure AI data, the organization shall:

  • Store AI data in encrypted databases with role-based access controls.
  • Regularly update AI security policies to address emerging threats.
  • Implement AI data lifecycle management, ensuring timely deletion of unused data.
  • Use blockchain or other tamper-proof methods for securing AI training data integrity.

7. AI Data Access Control

To prevent unauthorized access, the organization shall:

  • Restrict AI system access based on job roles and responsibilities.
  • Implement multi-factor authentication for AI data access.
  • Log and monitor AI data access activities for security audits.
  • Regularly review AI access permissions to prevent privilege misuse.

8. AI Data Anonymization and De-Identification

To protect personal data, AI systems shall:

  • Use anonymization techniques before storing sensitive user data.
  • Apply differential privacy methods to AI model training datasets.
  • Ensure AI-generated insights do not compromise user anonymity.

9. AI Data Sharing and Third-Party Compliance

AI data sharing must follow strict guidelines:

  • AI data should only be shared with authorized third parties under strict agreements.
  • External vendors must comply with ISO 42001:2023 and data protection regulations.
  • Data sharing agreements must specify security measures, purpose limitations, and retention policies.

10. AI Data and Documentation Retention Schedule

This schedule is the organization's single, defined and authoritative reference for how long the organization stores AI data, interaction logs, and system documentation, and satisfies the retention-period requirements of A.5.3, A.7.6, and 7.5.3. It is referenced by, and takes precedence over, any generic mention of "organizational data retention policy" or "records retention schedule" elsewhere in the AIMS document set (including the AIMS Manual Sections 6.2 and 8.1, B-001 Section 3.3.1, and B-007 Section 3.5.1).

Retention timelines are heavily risk-based: the AI System Owner determines the applicable AI system's risk tier from the AI Risk Assessment (6.1.2) and Impact Assessment (B-003), and applies the longer of (a) the period below or (b) any stricter period required by applicable law or contract. Data classified as PII is, in addition, subject to the Data Minimization principle (Section 3) and shall not be kept longer than necessary regardless of the maximum period stated below.

Data / Documentation CategoryStandard Retention PeriodHigh-Risk AI System RetentionBasis
AI training & validation datasets (non-PII)Life of model + 1 year post-decommissioningLife of model + 2 years post-decommissioningReproducibility, audit trail (A.7.5)
AI training data containing PIIAnonymized or deleted within 90 days of model finalization, unless a longer period is legally requiredSame, with mandatory DPIA re-review at 90 days (B-001 Section 2.2)Data minimization; GDPR/DPDPA 2023
Production / inference input-output data12 months rolling2 years rollingIncident investigation, model monitoring
Interaction logs (user queries, chatbot/agent sessions, model outputs)12 months2 yearsAudit trail, complaint investigation (AIMS-B-004)
System / technical event logs (model inference, data pipeline, infrastructure logs)Minimum 12 months, or the applicable regulatory minimum (e.g., TRAI/DoT), whichever is longerMinimum 2 yearsAIMS Manual Section 8.1; incident investigation and audit
AI system documentation (design docs, model cards, V&V/test reports, runbooks)Life of system + 1 years post-decommissioningLife of system + 2 years post-decommissioningTraceability, certification audit evidence (7.5.3)
AI System Impact Assessment ReportsMinimum 3 years from date of issue, or 3 years from decommissioning, whichever is longerSame (B-003 Section 3.10.1)A.5.3; consistent with B-003
AI Risk Register entries and risk treatment recordsLife of the AIMS + 2 yearsLife of the AIMS + 2 yearsGovernance continuity
AI security / data breach incident recordsMinimum 3 years from closureMinimum 5 years from closureRegulatory defensibility, recurrence analysis
Consent records (data subject consent for AI processing)Duration of processing + 2 years after withdrawal or processing endsSameDPDPA 2023 accountability requirements
Data subject access / erasure request records2 years from request closure2 years from request closureLegal defensibility
Internal / external AIMS audit recordsMinimum 2 yearsMinimum 2 years9.2, certification maintenance

Upon expiry of the applicable retention period, data and documentation shall be disposed of per the secure disposal methods defined in B-001 Section 3.3.2 (Secure Disposal Process). The GRC Team reviews this schedule at least annually, and upon any material change to applicable law, as part of the Continual Improvement process (10).

11. AI Data Breach Response and Incident Management

In case of AI data breaches:

  • The AI Governance Committee (AIGC) must be notified immediately.
  • Affected users and regulatory authorities must be informed per compliance requirements.
  • An AI security incident investigation must be conducted.
  • Preventive measures must be implemented to mitigate future risks.

12. AI Ethics and Responsible AI Use

To promote responsible AI use:

  • AI models must be designed to prevent discriminatory outcomes.
  • AI-generated decisions must be explainable and auditable.
  • Ethical AI guidelines must be integrated into AI development processes.
  • Employees must be trained on AI data ethics and security best practices.

13. Compliance with ISO 42001:2023 and Other Standards

This policy aligns with:

  • ISO 42001:2023 (Artificial Intelligence Management System)
  • ISO 27001 (Information Security Management)
  • ISO 9001 (Quality Management System)
  • GDPR and other data protection laws

More in AI data protection and responsible use

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