Licentia retains personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected or subsequently processed, unless a longer retention period is required or permitted by law, is necessary for lawful operational reasons, or is required for dispute resolution, legal enforcement, audit, or regulatory compliance. POPIA requires that personal information must not be kept longer than necessary, subject to recognised exceptions.

Where Licentia is no longer authorised to retain personal information, such information must be deleted, destroyed, de-identified, or restricted in accordance with applicable law and Licentia’s governance controls.

10.1 General Retention Principle

Licentia retains personal information for periods that are:

Where records are required for legal proceedings, investigations, enforcement, complaints, audits, or legal holds, Licentia may retain the relevant information beyond the ordinary retention period until the matter is finalised and the retention is no longer reasonably required. POPIA permits longer retention where retention is required by law, needed for lawful purposes related to the function or activity of the responsible party, required by contract, consented to by the data subject, or retained for historical/statistical/research purposes with safeguards.

10.2 Quotation / Enquiry Records

Information collected at the quotation or enquiry stage may be retained for a limited period for:

Where a quotation does not convert into an Active Client mandate/SLA, Licentia may retain the quotation and related enquiry records for up to 12 months, unless a shorter or longer period is justified by lawful business needs, dispute risk, repeated enquiries, or applicable legal requirements.

Quotation validity and reminder cycles may be managed operationally by Licentia’s systems, but expired quotations do not automatically require immediate deletion where retention remains lawful for audit, consent, or dispute purposes.

10.3 Active Client Mandates and Service Level Agreements

Where a client becomes an Active Client, Licentia may retain:

for the duration of the service relationship and thereafter for such further period as may be reasonably necessary for lawful recordkeeping, audit, enforcement, regulatory compliance, tax, FICA, contractual, or prescription-related purposes.

Where an SLA is ongoing, renewed, or continues annually, retention may continue for the duration of the service relationship and the applicable post-termination retention period.

10.4 FICA and Identity Verification Records

Where FICA, customer due diligence, identity verification, or transaction-related records are processed and retained, Licentia retains such records for at least five (5) years from:

as applicable under the Financial Intelligence Centre Act framework. Official FIC guidance confirms that customer due diligence and transaction records must generally be kept for at least five years from the end of the business relationship or the transaction date, as applicable.

Where an ongoing investigation, enforcement process, or lawful hold applies, such records may be retained for longer where lawful and reasonably necessary. Recent FIC guidance advises retaining records linked to ongoing investigations until the relevant law enforcement process is closed, where possible.

10.5 Financial, Tax, and Accounting Records

Licentia may retain invoices, quotations, receipts, proof of payment, payment allocations, financial workflow records, and related accounting records for the period required by applicable law and lawful financial governance requirements.

As a general rule, tax and accounting records are retained for at least five (5) years where required under applicable tax recordkeeping requirements. SARS guidance indicates that records, books of account, and documents must generally be kept for five years.

Where a longer retention period is required by law, audit, contractual dispute, investigation, or lawful governance needs, Licentia may retain the records for that longer period.

10.6 Company, Statutory, and CIPC-Related Records

Where Licentia processes company records, statutory governance records, CIPC-related documents, annual returns records, MOI-related records, share records, and similar corporate compliance records, such records may be retained for the period required by applicable company law and related governance obligations.

CIPC states that companies must keep certain company records and that a range of company records must be retained for seven (7) years.

Where a company, trust, NPO, or similar entity remains active, Licentia may retain core entity records for as long as they remain operationally or legally relevant, subject to lawful retention controls.

10.7 Regulatory, Licensing, and Compliance Records

Licentia may retain licensing, permit, certificate, inspection, readiness, compliance, municipal, environmental, health, fire, zoning, and regulatory correspondence records for as long as is reasonably necessary to:

Where a service category requires continuing compliance support, renewals, annual reporting, or recurring regulator engagement, the retention period may continue for the duration of that operational need and any applicable post-termination legal retention period.

10.8 Inspection Media, Photos, Video, and Evidence Packs

Inspection media, including photographs and video collected during site inspections, readiness assessments, and compliance processes, forms part of the official client file where relevant to the service provided.

Licentia may retain such media for so long as reasonably necessary to:

Where inspection media is no longer required and no lawful basis for retention remains, it must be deleted, destroyed, de-identified, or restricted in accordance with Licentia’s internal controls and POPIA requirements.

10.9 Communications, Audit Logs, and System Metadata

Licentia may retain communications records, system logs, consent logs, audit trails, access histories, and related metadata for so long as reasonably necessary to:

Because such records are often necessary to evidence lawful processing, security controls, and compliance oversight, they may be retained for longer than the underlying service interaction where reasonably justified.

10.10 Litigation, Legal Hold, Complaints, and Prescription

Where personal information is relevant to:

Licentia may place the relevant records on legal hold or otherwise retain them beyond standard retention periods until the matter is concluded and no further lawful retention basis remains.

As a general legal principle in South Africa, many civil claims prescribe after three years, subject to interruptions, suspensions, acknowledgements of debt, service of process, and specific statutory exceptions. Because prescription can be interrupted or delayed, retention decisions must be made case-by-case and not solely by reference to the passage of time.

10.11 Children / Minors Information

Licentia does not intentionally process children’s/minors’ information in the ordinary course of its services. If such information is incidentally included in lawfully required business records, Licentia will retain it only for so long as legally necessary and subject to heightened access control and confidentiality measures.

10.12 Destruction, Deletion, De-Identification, and Restriction

When Licentia is no longer authorised or required to retain personal information, it will take reasonable steps to:

POPIA provides that a data subject may request correction, deletion, destruction, or restriction in certain circumstances, and that a responsible party must respond as soon as reasonably practicable where the request is lawful and no overriding retention basis applies.

Where records cannot be deleted because a legal obligation, FICA requirement, tax requirement, legal hold, or dispute-related retention basis applies, Licentia may deny deletion and instead restrict the record and retain it only for the lawful retention purpose.

10.13 Lawful Basis

Retention of personal information is carried out on the basis of: