Expert knowledge for digital decisions
How to Implement Data Deletion Deadlines in CRM in Practice?
Short answer
The Structure of a Deletion Concept
Three specifications per data type:
| Data Type | Deadline | Begins With |
|---|---|---|
| Prospect without Business | e.g. 2 years | last contact |
| Customer, Contract Data | tax-related deadline | End of the Year |
| Newsletter Consent | until revocation | – |
| Application Data | e.g. 6 months | Rejection |
The specific deadlines depend on the individual case and must be coordinated with data protection and tax advisory services.
Delete or Restrict Access
Data relevant to invoices may not be deleted due to storage obligations. In this case: restrict access instead of deleting. The data record is retained for tax purposes but restricted for sales and marketing, and no longer appears in reports or campaigns.
This distinction is the most practically important point and is missing in most implementations.
Automated Instead of Manual
A monthly process that handles due data records and logs the action. Manual processing does not occur – not due to negligence, but because no one checks deadlines daily.
What Should Be Logged
What was deleted or restricted when, and on what basis. Without a log, the implementation cannot be proven.
The Most Common Error
Setting deletion deadlines only for main data. Attachments, email histories, logs, and backup copies are often forgotten. For backup copies, deletion in the active set is common, accompanied by exclusion of reuse.
This text does not replace legal advice.
Key facts
- Per Data Type
- Define deadline and trigger event
- Under Storage Obligations
- Restrict access instead of deleting
- Implementation
- Automated process with log
Sources
All external claims are backed by traceable sources.-
01
Datenschutz-Grundverordnung (Verordnung (EU) 2016/679) EUR-Lex / Europäische Union
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Ouhud CRM Ouhud GmbH