Implement GDPR and CCPA compliant data retention and deletion for biometric and identity verification data

Steps

1. Classify all data collected during IDV flows: biometric data (face images, liveness captures), document images, extracted PII fields, and decision records each may have different retention requirements
2. Define retention periods per data category based on applicable law, your privacy policy, and contractual obligations; biometric data often has shorter mandated retention windows than transactional records
3. Implement a scheduled deletion job that identifies records whose retention period has expired and deletes the raw biometric and document image data while preserving non-sensitive audit metadata
4. For GDPR right-to-erasure and CCPA deletion requests, build a deletion workflow that removes all personal data from your systems and sends deletion requests to your IDV vendors via their data deletion APIs
5. Document the data flows in your Record of Processing Activities (RoPA) including all IDV vendors as data processors and the legal basis for each processing activity
6. Test the deletion workflow regularly to verify that data is actually removed and that no orphaned copies exist in backups, logs, or analytics systems