rsRich Sadowski
Policy proposal · Work sample

AI Data Retention Policy

Sanitized work sample by Rich Sadowski. Written for a B2B SaaS company that processes customer data. The company name, product features, people and contract references are removed. Vendor quotes and legal sources are public and were confirmed on the date written.

A retention policy for the data that a SaaS product's AI features create and process: prompts, inputs, outputs, AI-derived values and AI system logs. Each policy item is paired with what peer software vendors publish, and the document closes with the legal and audit basis.

01Background

The company is a B2B SaaS platform. For customer data it acts as a processor, and its customers are the controllers. AI features run on commercial models reached through Microsoft Azure OpenAI, Google Vertex AI and Databricks, and through embedded analytics and text-analytics vendors.

Customer AI questionnaires now ask how long each category of AI data is kept and whether it is deleted with the customer's other data. With no single published answer, each request is answered one email at a time. A defined policy lets Compliance answer these requests without Product involvement.

Existing positionCurrent statement
★ Customer data after contract endDeleted from the database 30 days after end of contract. Removed from backups after 60 days.
Audit and access logsRetained 90 days.
Third-party model trainingThird-party AI providers may not use customer data to train or fine-tune generative AI models.
The company's own modelsThe customer agreement permits training on aggregated data. The DPA permits de-identification into anonymized aggregated datasets.

02Proposed policy

Six items, each with published peer practice.

1. AI results are kept with the customer record they belong to

AI-generated content, AI-assisted edits, and AI-derived values such as sentiment and theme scores are stored as customer data. They follow the customer's data retention policy and are deleted 30 days after contract end, and from backups after 60 days.

Who else does this

2. AI system logs are kept 90 days and deleted by date

Operational AI logs are deleted automatically on a fixed period of 90 days, matching the platform log standard. Retention is set by date, not by a count of entries.

Who else does this

3. LLM providers retain nothing

Every model provider operates under zero data retention. Where a provider cannot offer it, the company discloses that provider's retention window.

Who else does this

4. Fine-tuning uses de-identified, aggregated data only

Product may retain data for as long as it is needed to improve features, provided the data is de-identified and aggregated as the customer agreement and DPA allow. Raw prompts and responses are not retained for tuning.

Who else does this

5. Termination deletes all AI data

On contract end, AI inputs, outputs, logs and any of that customer's tuning sets not yet aggregated are deleted on the same schedule as other customer data.

Who else does this

6. Retention periods are published on the Trust Center

The periods in items 1 to 5 are published, so Compliance can answer AI retention questions directly.

Who else does this
Why not "as long as there is a valid business reason"None of the 23 vendors reviewed uses open-ended retention as its main rule for AI data. The common pattern is a fixed period or deletion with the customer's account. As a processor, the company may keep customer data only on the customer's documented instructions. The business reason is kept by writing each one down with a period attached, which items 1 to 5 do.

03Legal and audit basis

SourceRequirement
★ GDPR Art. 28(3)(a)A processor "processes the personal data only on documented instructions from the controller" [21]
★ EDPB Guidelines 07/2020, p. 4"A processor infringes the GDPR, however, if it goes beyond the controller's instructions and starts to determine its own purposes and means of the processing. The processor will then be considered a controller in respect of that processing" [22]
CCPA §1798.100(a)(3)"The length of time the business intends to retain each category of personal information... or if that is not possible, the criteria used to determine that period" [23]
FTC, January 2024Companies have promised "that they won't use customer data for secret purposes, such as to train or update their models" [24]
FTC, Everalbum (2021)The company was required to delete "the models and algorithms it developed by using the photos and videos uploaded by its users" [25]
CSA CCM v4 DSP-16"Data retention, archiving and deletion is managed in accordance with business requirements, applicable laws and regulations." [26]

04Inputs needed to adopt

OwnerInput
Data platform leadWhether a zero data retention arrangement is in place with Databricks.
Product engineering leadThe model and version behind each AI feature, and confirmation that AI-generated entries are deleted with the record they belong to.
Product leadershipAgreement to items 2 and 4, including the 90-day log period and the aggregation requirement for tuning data.
LegalReview of item 4 against the DPA's de-identification clause.

05References

All links opened and quotes confirmed on the date written (October 2026).

[1] Medallia, Trust Center. https://trust.medallia.com

[2] Microsoft, Data, Privacy, and Security for Microsoft Copilot. https://learn.microsoft.com/en-us/copilot/microsoft-365/microsoft-365-copilot-privacy

[3] Microsoft, Learn about retention for Copilot and AI apps. https://learn.microsoft.com/en-us/purview/retention-policies-copilot

[4] Slack, Slack AI data handling. https://slack.com/help/articles/28310650165907

[5] Gong, Trust. https://www.gong.io/platform/trust

[6] Notion, Trust controls. https://trust.notion.com/controls

[7] Salesforce / Tableau, Tableau AI usage. https://help.tableau.com/current/tableau/en-us/tableau_gai_usage.htm

[8] OpenAI, Your data (API). https://developers.openai.com/api/docs/guides/your-data

[9] Anthropic, How long do you store my data? https://privacy.claude.com/en/articles/7996866

[10] Databricks, Model Serving. https://docs.databricks.com/aws/en/machine-learning/model-serving

[11] Qualtrics, Qualtrics commitment to secure and private AI. https://www.qualtrics.com/news/qualtrics-commitment-to-secure-and-private-ai/

[12] Zendesk, Generative AI at Zendesk. https://support.zendesk.com/hc/en-us/articles/6059285322522

[13] Zendesk, Zendesk AI Data Use Information. https://support.zendesk.com/hc/en-us/articles/5729714731290

[14] Atlassian, Atlassian Intelligence trust. https://www.atlassian.com/trust/atlassian-intelligence

[15] Intercom, Security. https://www.intercom.com/security

[16] ThoughtSpot, Spotter versions. https://docs.thoughtspot.com/cloud/26.9.0.cl/spotter-versions

[17] Sprinklr, AI+. https://www.sprinklr.com/products/platform/ai-plus/

[18] SurveyMonkey, Trust Center. https://www.surveymonkey.com/learn/trust-center/

[19] Google Workspace, Protecting your data in the era of generative AI. https://workspace.google.com/blog/identity-and-security/protecting-your-data-era-generative-ai

[20] HubSpot, HubSpot machine learning data. https://knowledge.hubspot.com/account-management/hubspot-machine-learning-data

[21] GDPR, Article 28, Processor. https://gdpr-info.eu/art-28-gdpr/

[22] EDPB, Guidelines 07/2020 on controller and processor. https://www.edpb.europa.eu/system/files/documents/2023-10/EDPB_guidelines_202007_controllerprocessor_final_en.pdf

[23] California, CCPA, Civil Code 1798.100. https://cppa.ca.gov/regulations/pdf/cppa_act.pdf

[24] FTC, AI companies: uphold your privacy and confidentiality commitments (January 2024). https://www.ftc.gov/policy/advocacy-research/tech-at-ftc/2024/01/ai-companies-uphold-your-privacy-confidentiality-commitments

[25] FTC, Everalbum settlement (May 2021). https://www.ftc.gov/news-events/news/press-releases/2021/05/ftc-finalizes-settlement-photo-app-developer-related-misuse-facial-recognition-technology

[26] Cloud Security Alliance, CCM v4 DSP-16 Data Retention and Deletion. https://csf.tools/reference/cloud-controls-matrix/v4-0/dsp/dsp-16/

Rich Sadowski · richsadowski.com
A proposal for discussion. Peer vendor statements are quoted from public pages as they read in October 2026 and may change.