GDPR and KYC: Data Retention, Storage, and Subject Rights
GDPR says minimise. AML says keep for 5 years. Here is the actual reconciliation regulators expect.
The tension between GDPR data minimisation and AML/CTF retention requirements is real but resolvable. The trick is treating them as overlapping, not conflicting.
Retention by data type
- Identity documents: 5 years post-relationship (EU MLR)
- Transaction records: 5 years post-transaction
- Communications: 5 years post-relationship
- Failed-applicant data: 6 months unless fraud suspected
Subject access requests
Customers can request their data, but AML-retained records are exempt from erasure during the retention window. Document the legal basis on every record.
How we handle it
We are a processor for verification data with country-pinned storage, configurable retention, and a documented DSAR workflow.
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