Hold evidence for a case or an appeal
Place a legal hold so evidence is kept past its retention while a complaint, an inquiry or an appeal runs, then release it.
Place a hold when evidence must outlive its retention. A person may complain to the Data Protection Board, the Board may start an inquiry, or an order may go to appeal. A hold covers one person, one record or the whole project.
Before you start#
You are an Owner or a Privacy officer of the project. An Auditor can see the holds but cannot place or release them.
Place a hold#
- Open Audit.
- Choose Legal holds, then Place a hold.
- Under What it covers, choose One person, One record or Whole project.
- For one person, type The person’s identifier and, if you know it, the Kind of identifier.
- For one record, type the Consent id of the record.
- Fill in the Reason for the hold and the Case reference, such as
TDSAT Appeal No. 14 of 2027. - Choose Place the hold.
The identifier is hashed as it arrives and never stored. The hold keeps the keyed hashes, and shows their first 12 characters. It covers the person's records under that identifier and those linked to it. The audit log keeps only the first 12 characters of each hash.
Each hold in force shows how many records it keeps.
What a hold keeps#
| While a hold is in force | What happens to held records |
|---|---|
| Deletion under Keep evidence for | Skipped, with their events |
| Removal of test records after 30 days | Skipped |
| An erasure | Goes ahead as usual, except that the IP address hash, the browser, the page and metadata stay |
| Details kept for a year after an erasure | When the year is up, the encrypted identifier and the subject fingerprint go. The logs stay |
| Closing the project | Waits until the last hold is released |
Erasing a person's identifiers is their right, so a hold never stops it. The sealed record, its events and its daily anchors stay.
Release a hold#
- In Legal holds, find the hold and choose Release the hold.
- Fill in Why it is released, such as
Appeal decided on 12 March 2028. - Choose Release the hold.
The hold moves under Released. What it kept is then deleted at the end of its retention, like any other evidence. To hold it again, place a new hold.
Tell your systems#
Endpoints that receive legal_hold.placed and legal_hold.released are told of each hold, so your own systems can keep their copies too. See Other events.