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There is no single retention period that works for every organization or every kind of identity data. Keep identifiable records only while they are necessary for a stated purpose or a valid legal, regulatory, contractual, or policy requirement. Set a deadline to erase or review each category, and then delete it, narrow it, or anonymize it when continued identification is no longer justified.
How long can personal data be kept?
As long as the organization can justify keeping it for a defined purpose or applicable requirement—and no longer than necessary. The European Commission’s GDPR principles say personal data should be stored for the shortest time possible, taking account of why it is needed and any fixed legal retention duties. Organizations should set time limits for erasure or review. European Commission: Principles of the GDPR
That principle does not establish one universal number of days or years. The appropriate period depends on the organization’s jurisdiction and sector, the type and sensitivity of the record, its purpose, and applicable laws or records policies. The GDPR applies within its scope; NIST’s digital identity guidance provides identity-specific practices but does not replace legal analysis for an organization’s other records.
Where no mandatory retention period applies, NIST SP 800-63B-4 says the verifier or the identity provider (IdP) should assess privacy and security risks to decide how long to retain records and inform subscribers of the policy. NIST SP 800-63B-4: Authentication and Authenticator Management
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Which identity records should have separate retention rules?
Do not treat “identity data” as one record with one clock. Use an inventory to identify what is held, where it is held, why it is needed, and who can access it. The following categories are a practical starting point, not a prescribed NIST list:
- Identity-proofing evidence: documents, verification results, and other evidence used to establish a claimed identity.
- Account attributes: information associated with an account or shared with a relying party (RP), the service that uses an identity provider’s assertion to make an access or authorization decision.
- Biometric information: biometric samples, templates, or related records. Treat these as a distinct, high-sensitivity category.
- Authenticator records: records about credentials or devices used to authenticate a subscriber.
- Authentication records: logs and events associated with sign-ins or authentication attempts.
- Fraud, security, audit, or dispute records: evidence retained to support a specific security, audit, or dispute-handling purpose.
- Downstream copies: identity data held by service providers, RPs, or other systems that received or processed it.
For each category, identify the purpose, users, locations and copies, any applicable retention requirement, the minimum evidence needed, and a deletion or review trigger. NIST SP 800-63A says identity-proofing providers must tell applicants the purpose of processing, the attributes collected, any retention requirement, and how to request deletion or redress. It also limits processing to the minimum necessary for identity validation, fraud mitigation, and providing attributes to RPs. NIST SP 800-63A: Identity Proofing and Enrollment
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How should an organization choose a retention period?
Use a documented decision for each category rather than borrowing a period from another organization or applying one account-wide rule. Compare the purpose and need for the data with mandatory requirements, the risks of keeping it, and whether a less identifying record would still serve the remaining need.
- State the purpose. Record what the data supports, who uses it, and what decision or service would be affected if it were removed.
- Check for a binding requirement. Have the relevant legal, compliance, records-management, or contract owner determine whether a law, regulation, contract, or records schedule requires the record to be kept, and for how long. Do not assume that a general operational preference is a mandatory retention duty.
- Identify the minimum necessary record. Decide which evidence or attributes are actually needed. Consider whether a reduced, pseudonymized, anonymized, or aggregated record can meet a continuing need without retaining the original identifiable data.
- Assess risks if no mandatory period applies. Consider privacy and security risks from continued retention, alongside any supported account recovery, fraud prevention, audit, or dispute-handling need. NIST SP 800-63B-4 calls for risk assessment to determine retention duration when there is no mandatory requirement and for subscribers to be informed of the resulting policy.
- Set a deadline and trigger. Specify a deletion date or a review point tied to an event, such as the end of a documented purpose or account termination. A review is not permission to keep the data indefinitely: record the outcome and the basis for any extension.
- Record the decision and communicate it. Document the rationale, responsible owner, applicable exception, and how the retention rule is explained to subscribers.
There are no general-purpose identity-data durations established by the cited guidance. NIST SP 800-63C gives example inactivity intervals in a discussion of service usage patterns; those examples are not recommended retention periods for identity data. NIST SP 800-63C: Federation and Assertions
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When should we delete identity data?
Delete or de-identify records when the purpose for keeping identifiable information ends, the applicable retention period expires, or a review finds no continuing justification—unless a specific requirement prevents deletion. Apply the decision to every system and copy covered by the policy, not just the main account database.
For an account that is closing, separate three actions in the procedure: terminate access, remove or de-provision accounts and attributes where appropriate, and retain only the limited evidence that a documented requirement still calls for. These actions may have different triggers. NIST SP 800-63C says an IdP should de-provision an RP account after termination unless RP retention requirements, policy, or regulation prevent it; upon termination, personal information should be removed under the applicable process.
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- Make the deletion or review owner responsible for the primary system and for communicating the decision to relevant service providers and RPs.
- Track downstream copies and confirm deletion or the reason an exception applies.
- Keep any exception narrow: identify the specific records, requirement, owner, and review or end point rather than retaining an entire identity profile by default.
- Where a longer archive is justified, consider whether anonymization or pseudonymization can reduce the identifying information retained. The European Commission identifies these as possible safeguards for longer public-interest archiving or research retention.
What is different about biometric retention?
Biometric information warrants its own documented rule rather than being swept into a general account-retention period. 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 biometrics unless law, regulation, or policy restricts deletion. Include the request route, decision owner, applicable exceptions, and deletion process in the biometric policy.
What should a usable retention schedule contain?
A schedule should make each rule actionable for the people and systems that must follow it. At minimum, record:
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- the record category and systems or parties holding it;
- the stated purpose and the minimum data needed for that purpose;
- the applicable legal, regulatory, contractual, or records-management requirement, if any;
- the chosen retention period or event-based review trigger, with a documented rationale where no mandatory duration applies;
- the deletion, de-identification, or review action and the responsible owner;
- how subscribers are told about collection, retention, and available deletion or redress requests; and
- any exception, the records it covers, why it blocks deletion, and when it will be reviewed.
Review the schedule when the purpose, systems, service relationships, or applicable requirements change. A rule that works for proofing evidence may not fit authentication logs or a downstream RP account; keep the categories distinct enough to apply the right action to each.
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