Smart device data retention: how long to keep it?
Set a justified retention period for each purpose, with a clear starting event and deletion action. Apply it to recordings, telemetry and account data wherever copies sit, then test expiry, account closure and backup handling. Factory-side sourcing checks can be coordinated by Cambridge China Bridge.
Start with the purpose, not the storage capacity
ICO guidance says personal information from smart devices must not be kept longer than needed. Data protection law sets no universal retention period: the period depends on your situation and processing purposes. Do not adopt the factory's storage capacity or cloud subscription allowance as your justification.
Before approving a supplier, map what the device collects, why it is needed and where it goes. Include removable storage, phone caches, cloud databases, support exports and backups. For the separate product security documentation, use our connectable products guide.
Write a schedule for each use
Create a schedule with the data category, purpose, retention period, starting event, justification, storage locations, deletion method and responsible owner. Choose and document actual periods before launch. Treat the examples below as questions to resolve, rather than prescribed deadlines.
Separate raw recordings from saved clips, operational telemetry from diagnostic logs, and account access details from support correspondence. If you propose keeping information for another purpose, document that purpose and its retention decision separately.
| Data and purpose | Starting event to define | Decision and deletion check |
|---|---|---|
| Recordings used for playback | Capture time | Justify the playback window; check automatic expiry of recordings and thumbnails. |
| Clips saved for a reported incident | Saving or incident closure | Document why the clip remains needed; give saved copies their own expiry. |
| Telemetry used to diagnose faults | Collection or support-case closure | Justify the diagnostic window; check raw logs and exported support files. |
| Account data used to operate the service | Account closure or a defined inactivity event | Separate access credentials, device links and correspondence; specify what each deletion action removes. |
| Backups used for recovery | Backup creation | Define replacement and restoration handling; prevent deleted records returning to active use. |
Make deletion work across the whole product
Ask the factory, app developer and cloud operator to demonstrate separate actions for deleting a recording, closing an account and resetting a device. Check local storage, cached previews, cloud copies, search indexes and support exports. Do not accept disappearance from the app screen as proof that every copy has gone.
Specify how an offline device receives a pending deletion when it reconnects. Test whether synchronisation uploads an expired recording again, and whether a reset leaves the previous account linked to the device. Record the approved firmware, app and cloud configuration using our software approval guide.
Agree supplier and backup handling
ICO guidance recommends agreeing what happens when information shared with other organisations is no longer needed. Name who operates each storage location, who triggers deletion and who confirms completion. Include the factory's support team and any provider holding diagnostic exports.
For a valid erasure request where no exemption applies, ICO guidance says deletion steps must cover backups as well as live systems. Explain backup handling clearly to users. Where immediate overwriting is unavailable, put the backup data beyond use pending scheduled replacement. Ask the provider to demonstrate that restoration does not return deleted data to active use.
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Test expiry and keep the schedule current
Use a sample account with recognisable test recordings and telemetry. Exercise automatic expiry, manual deletion, account closure, reset, offline reconnection and backup restoration. Ask for evidence from each storage location and record unresolved failures before approving production. For camera-specific sourcing checks, see our CCTV guide.
ICO guidance recommends reviewing retention periods regularly and erasing or anonymising personal information when it is no longer needed for its purpose. Revisit your schedule when features, support workflows or providers change. Keep a deletion log that records outcomes without reproducing the recordings or telemetry being removed.
Frequently asked questions
Does the ICO prescribe a smart-device retention period?
No universal period is prescribed. Set and justify periods according to your situation and each processing purpose.
Does deleting the app delete my customer's data?
Do not assume it does. Test device storage, app caches, cloud copies and support exports separately, using an agreed deletion procedure.
Can recordings and telemetry share a retention period?
Only choose a shared period if you can justify it for each purpose. Separate schedules make different needs and deletion triggers easier to check.
Do backups need to be included in deletion?
Yes. ICO guidance says a valid erasure request, where no exemption applies, requires steps covering backups and live systems. Define replacement and restoration handling.