Policy template / v1.1

Decide what your AI audit trail keeps, why, and for how long.

A working policy template for event scope, retention periods, legal holds, integrity checks, access control, verified deletion, and evidence exports.

Format
Editable Markdown
Release
v1.1 / Jul 16, 2026
Access
Free / no email

General information and a drafting aid. Legal, privacy, and records-management review remains required.

Control record / retention

Audit log retention policy

Reviewable
Version
1.1
Owner
Risk operations
Review
Annual

Retention register

Sample entries

High-risk AI logs6+ months
Decision records7 years*
Tool and data access24 months*
Legal holdUntil release

* Illustrative period. Replace it with a documented requirement and approved purpose.

Integrity / access / disposal / export

K

Regulatory baseline

Start with the obligation. Record the basis for every period.

The template separates the minimum baseline from the longer periods that may come from sector rules, contracts, disputes, or an approved operational purpose.

EU AI Act

Articles 19(1) and 26(6)

High-risk AI system logs

Providers and deployers keep automatically generated logs under their control for a period appropriate to the system’s intended purpose, with a minimum of six months unless applicable Union or national law provides otherwise.

Read the official regulation

GDPR

Article 5(1)(e)

Storage limitation

Personal data remains identifiable only for as long as the processing purpose requires. The schedule should document necessity, minimization, deletion, and any valid exception.

Read the official regulation

Your context

Sector / country / contract

Additional retention requirements

Sector rules, national law, contractual commitments, investigations, and legal holds can change the applicable period. The retention register captures the exact source, owner, trigger, and review date for each decision.

Seven years appears only as an editable example. Every selected period needs a documented legal, regulatory, contractual, or operational basis.

Policy coverage

Six decisions make the policy operational.

Each section closes a gap that reviewers commonly find between a written retention statement and the systems expected to enforce it.

Event scope

SCOPE

Name the decisions, approvals, tool calls, data access events, configuration changes, and administrative actions covered by the policy.

Retention clock

CLOCK

Define when each period starts: event time, case closure, incident closure, contract end, or release of a legal hold.

Period and basis

BASIS

Record the selected period beside its legal, regulatory, contractual, or approved operational basis.

Exceptions and holds

HOLD

Specify who can suspend deletion, how the affected scope is identified, and what releases the hold.

Verified disposal

DISPOSE

Define the deletion method, approval path, retry behavior, and the evidence produced after disposal.

Integrity and export

PROVE

Document append-only storage, integrity checks, access controls, export contents, and independent verification steps.

Working register

Put the decision beside the evidence it must produce.

This example shows the level of specificity the downloadable template asks for. Replace every sample period and basis with your approved requirements.

Event classClock startsPeriodBasisDisposal evidence
High-risk AI system logsEvent recordedAt least 6 monthsEU AI Act Articles 19(1) and 26(6)Deletion run and exception report
Decisions and approvalsDecision closed7 years - exampleNamed sectoral, contractual, or internal requirementApproved deletion report
Tool calls and data accessProcess run closed24 months - exampleIncident analysis and accountability purposeDeletion manifest
Operational telemetryMetric captured90 days - exampleService operations purposeScheduled job report
Records under legal holdHold issuedUntil releaseApproved hold noticeRelease approval and disposal report

Illustrative schedule only. The six-month entry reflects the EU AI Act baseline for relevant high-risk AI system logs. Other periods require context-specific review.

Inside the file

A working document, ready to edit.

Sixteen policy sections, a starter retention register, a control test record, and approval fields. The file stays readable in source control and exports cleanly into your document system.

  • Regulatory and contractual requirement inventory
  • Event taxonomy and system scope
  • Retention, legal hold, and disposal procedures
  • Integrity, access, vendor, and export controls
  • Evidence register and control test record
Download v1.1
audit-log-retention-policy-template.mdExcerpt
## 5) Retention register

| Event class | Clock starts | Period | Basis |
| --- | --- | --- | --- |
| Decision records | Decision closed | [period] | [source] |
| Tool calls | Process run closed | [period] | [purpose] |

For each row, record:
- System owner and data owner
- Personal data fields and minimization controls
- Legal hold behavior
- Deletion method and verification record
- Review date and approving roles

## 10) Legal holds

- Hold authority: [role]
- Scope identification method: [query / case IDs]
- Release approval: [roles]
- Evidence retained: [notice / actions / release / disposal]

Implementation

Take the policy through one complete control test.

A signed document establishes the decision. A tested hold, deletion, and export shows that the control operates as written.

  1. 01

    Map the records

    Inventory systems, event classes, data fields, owners, storage locations, and downstream copies. Identify which records contain personal or sensitive data.

  2. 02

    Decide and approve

    Set the retention trigger and period for each class. Attach the exact source or approved purpose, then route privacy, legal, security, and system-owner review.

  3. 03

    Configure the controls

    Implement deletion schedules, legal holds, access boundaries, integrity verification, failure alerts, and vendor obligations.

  4. 04

    Test the evidence

    Run a sample hold, release, deletion, and export. Retain the approvals, job reports, exception records, manifest, checksums, and verification result.

KLA evidence flow

Carry the policy into the Audit Trail and Evidence Room.

KLA connects the approved retention decision to runtime records, control checks, and a verifiable export for reviewers.

01

Approved policy

Version, owner, scope, schedule, and exceptions

02

Audit Trail

Access, hold, deletion, and export actions

03

Assurance record

Integrity checks, failed jobs, and remediation

04

Sealed Evidence Bundle

Manifest, checksums, records, and verification result

Questions

Retention policy questions, answered plainly.

Use these answers to frame the first review with legal, privacy, security, records management, and system owners.

How long should we retain AI audit logs?

For relevant high-risk AI systems, EU AI Act Articles 19(1) and 26(6) set a minimum of six months for automatically generated logs under the provider or deployer’s control, unless applicable Union or national law provides otherwise. Your final period must also account for privacy, sector, national, contractual, and legal hold requirements.

What does “tamper-evident” mean for logs?

That unauthorized changes are detectable. Common approaches include append-only storage, hash chaining, and periodic integrity verification with retained reports.

Do we need to log model outputs and prompts?

Keep enough context to explain the decision and verify the control. Apply data minimization, redaction, hashing, or controlled references where full content would create unnecessary privacy or security risk.

How do we handle legal hold?

Define a retention override that prevents deletion for specified scopes, and ensure all hold actions are logged and approved.

What do auditors want to see in exports?

A scoped bundle of relevant records, the approved policy and configuration, a manifest, checksums, access and export history, and clear instructions for independent integrity verification.

Is seven years required for every AI audit log?

Seven years is an editable example in this template. Use it only when a documented legal, regulatory, contractual, or approved operational basis supports that period.

Editable policy / v1.1

Put the retention decision on record.

Download the complete Markdown template, assign the owners, and review the first schedule against your actual systems and obligations.

Audit Log Retention Policy Template | KLA