GDPR Deletion Periods & Deletion Concept Explained

Sascha LadewigBy Sascha Ladewig· Founder & CEO· Updated: July 25, 2026

In short: Personal data may only be stored as long as necessary for the purpose or due to statutory retention obligations (storage limitation, Art. 5 GDPR). After that, it must be deleted. A deletion concept defines which data is deleted when and how.

The tension: retain vs. delete

On one hand, commercial and tax law require many documents to be retained for years. On the other, the GDPR requires deletion once the purpose no longer applies (Art. 17 – right to erasure). The solution: data with a retention obligation is kept/blocked until the period expires and then reliably deleted.

The deletion concept (DIN 66398)

A deletion concept assigns data types to deletion classes with defined periods and sets responsibilities and procedures. Typical building blocks:

  • Inventory of data types and their legal bases
  • Deletion periods per data type (start, duration)
  • Deletion procedure and evidence
  • Responsibilities and controls

Sovereignty and processing

Where data is stored is part of GDPR compliance. Hosting in German data centres without US subcontractors avoids the uncertainties of third-country transfers. For the software you use, you need a data processing agreement (DPA).

How Aktenplatz helps

Retention periods can be stored per document; after expiry you delete in a GDPR-compliant way – automatically or after approval. Fine-grained permissions, a complete audit trail and hosting in Germany support a robust deletion concept.

Note: This article offers general guidance to the best of our knowledge (as of 2026) and does not constitute legal or tax advice. The applicable statutory rules and your tax adviser are authoritative.

Frequently asked questions

Do I have to delete data despite a retention obligation?

During a statutory retention period the data may and must be kept. Only after the period expires does the GDPR deletion duty apply.

What is a deletion concept?

A deletion concept (guided by DIN 66398) assigns deletion periods to data types and defines procedures and responsibilities so personal data is deleted reliably and verifiably.

Why does the hosting location matter?

The storage location determines third-country transfers. Hosting in German data centres without US subcontractors reduces legal uncertainty and strengthens GDPR compliance.