Keeping personal information: set a period, then destroy it
There is no single number of years that fits every record. The rule is written per category, and destruction has to be shown.
Since September 2023, the privacy policy has to state retention periods, or the criteria used to set them. Law 25 requires you to stop keeping information once the purposes are achieved, unless another statute forces you to keep it. A table that says seven years for everything meets neither requirement.
Start from the purpose, not from a round number
For each activity, write down why you collect the information. The period follows that purpose. A résumé is used to fill a role. A client file is used to perform the contract and answer a claim. A connection log is used to detect an incident. Once the purpose is done, you keep the record only if a specific legal duty remains.
Do not paste the tax period onto everything else
Books and records for tax purposes are generally kept for six years after the end of the last tax year they relate to, for both the Canada Revenue Agency and Revenu Québec. That period covers accounting documents. On its own, it does not cover job applications, call recordings, copies of identity documents or technical logs.
Examples of internal rules
These periods are examples an organization can adopt. They are not legal minimums. Adjust them to your own duties, then write them into the policy.
| Category | Example of a rule |
|---|---|
| Unsuccessful applications | 12 months after the decision, then destruction |
| Clients | Life of the contract, then the tax and limitation periods that apply to the file |
| Prospects | Until withdrawal, or 24 months without interaction |
| Technical logs | 6 to 12 months, longer only if an investigation is open |
| Employees | Length of employment, then the periods set by employment and tax statutes |
Destroy it, and be able to show that you did
- Paper goes through shredding, or through a provider that returns a certificate.
- Files are removed from production. Backup copies follow the rotation cycle. Promising instant erasure of every tape is rarely true.
- A device that is reused or discarded is wiped before it leaves the department.
- A log records the date, the category, the method and the person responsible. Without that log, the rule stays an intention.
Periods tied to activities, not to a spreadsheet on its own
CapPRP links the processing register, retention periods and proof of destruction.