Compliance glossary
Definition

Retention and Disposal

Policies that govern how long client data is kept and how it is securely destroyed when it is no longer needed.

What it means.

Retention and disposal policies define how long a firm keeps client data and how it is securely destroyed when retention periods expire. The FTC Safeguards Rule requires secure disposal of customer information (16 CFR 314.4(c)(6)) and applies the broader Disposal Rule under 16 CFR Part 682. Retention periods vary by record type: federal tax records often three to seven years, state records may be longer, IRS requirements may impose specific minimums. Disposal must render data unreadable: shredding for paper, cryptographic erasure or physical destruction for digital media.

Why it matters for CPA firms.

Keeping data longer than necessary inflates breach exposure and may violate state privacy laws. Disposing of data incorrectly (recycle bin, throwing out an old laptop without wiping it) is a notifiable breach. A documented retention schedule and disposal procedure protects the firm in both directions. The FTC has fined firms specifically for improper disposal.

Relevant regulations.

  • 16 CFR 314.4(c)(6)
  • 16 CFR Part 682 (FTC Disposal Rule)
  • IRS Publication 4557

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