Enabling Privacy Compliance Through Defensible Data Lifecycle Management

A global asset management firm faced growing regulatory scrutiny around its data retention practices and privacy compliance posture. The firm had accumulated vast volumes of legacy records across multiple geographies, including sensitive personal data subject to GDPR, CCPA, and other evolving privacy regulations. Despite the presence of policies on paper, there was no centralized governance function to enforce lifecycle rules, no clear data ownership, and no effective process for disposal of unneeded data.

With increasing audit pressure and rising data storage and eDiscovery costs, the firm engaged Arrayo to help design and operationalize a global information governance program that would enable defensible disposal, regulatory alignment, and cross-functional accountability.

Delivery

Arrayo collaborated closely with the Legal, Information Security, eDiscovery, Privacy, and IT functions to lead the strategy, design, and implementation of a global information governance framework. The project was delivered across the following core workstreams:

• Retention Schedule Design: Developed a global records retention schedule grounded in regulatory, legal, and business requirements across all jurisdictions. This included harmonization across regions and clear mappings to business records and systems.
• Governance Framework Development: Designed a tiered governance structure for Information Governance (IG), including roles and responsibilities for data stewards, records coordinators, and legal/privacy SMEs.
• Privacy & Compliance Alignment: Aligned lifecycle rules with privacy obligations under GDPR, CCPA, LGPD, and PIPEDA. Worked in coordination with Privacy teams to ensure that records retention periods supported data minimization and lawful retention principles.
• Defensible Disposal Enablement: Created defensible disposal guidelines, exception workflows, and legal hold validation processes to allow for compliant deletion of legacy and redundant data. Facilitated working groups to validate record classes and identify deletion candidates.
• Cross-Functional Stakeholder Engagement: Led regular governance forums to coordinate across legal, compliance, IT, and records management teams. Developed change management and onboarding plans for key business units to adopt the new framework.
• Technology Strategy & Integration: Assessed and supported implementation of enabling technologies, including records management systems, privacy tools, and data discovery platforms.

Value

• Multi-million Cost Avoidance: Enabled defensible disposal of redundant, obsolete, and trivial (ROT) data, reducing legal exposure and saving millions in eDiscovery and storage costs.
• Audit-Ready Governance Structure: Established a documented and sustainable governance model with clear ownership, enabling readiness for regulatory exams and internal audits.
• Cross-Border Privacy Compliance: Integrated lifecycle governance with global privacy laws, supporting compliant data retention and defensible deletion across regions.
• Risk Reduction: Minimized litigation and regulatory risk exposure by reducing unneeded sensitive data and establishing traceable accountability.
• Sustainable Lifecycle Management: Laid the foundation for long-term records governance by embedding IG principles into operational processes and privacy-by-design efforts.