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Data Retention Policies

Firmly provides configurable retention periods for investment conversations, audit logs, and deal documents. Policies can be set at the firm level with fund-specific overrides, allowing you to align data lifecycle management with your regulatory requirements and investor agreements.

Why Retention Policies Matter in Investment Management

Investment firms must balance competing requirements:

  • Retain records long enough to meet SEC books and records requirements (typically 5-7 years) and respond to investor inquiries
  • Minimize data exposure by not retaining sensitive deal information longer than necessary, reducing breach risk

What Can Be Configured

Firmly allows independent retention periods for different data types:

  • Investment conversations — AI-assisted discussions about deals, portfolio analysis, and market research
  • Audit logs — Records of who accessed what investment information and when
  • Deal documents — Uploaded term sheets, financial models, due diligence materials, and research reports

Each data type can have its own retention period, and funds can override firm defaults when investor agreements or regulatory requirements differ.

Typical Investment Retention Periods

Data Type Typical Requirement
Investment conversations 5-7 years (SEC Rule 204-2)
Audit logs 5-7 years (SEC requirement)
Deal documents 5-7 years or life of investment + 5 years

Note: Always consult your CCO and legal counsel to determine appropriate retention periods for your firm's specific regulatory obligations and investor agreements.

How Retention Works

  • Retention cleanup runs automatically on a scheduled basis
  • Data older than the configured retention period is eligible for deletion
  • Audit logs are archived before deletion to preserve integrity verification
  • All deletions are permanently documented for compliance reporting

Legal Hold Override

Data subject to a legal hold is never deleted by retention policies, regardless of age. This ensures compliance with preservation requirements during SEC examinations, investor litigation, or internal investigations.

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