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Best Practices Information Governance Can Prevent (or at least mitigate) Catastrophic Data Breach: The Case of Allium UPI in Estonia




Earlier this year, a data breach at Allium UPI, compromised the personal information of nearly half of Estonia’s population. This type of catastrophic breach underscores the vital importance of data deletion based on a clear retention schedule.


Privacy regulations, such as the GDPR, mandate that personal data be kept only as long as it serves a specific business or legal purpose, which includes complying with a retention schedule based on EU law.


Simply put, when personal data is both no longer necessary and not required to be kept based on a legal retention requirement, it should be deleted promptly to reduce the risk of exposure.


Why Data Deletion Matters


Regularly deleting data in line with a retention schedule isn’t just a compliance requirement; it’s a proactive security measure.


In the case of Allium UPI, the exposed data included backups dating back to 2014, which may no longer have had any business or legal necessity. Storing outdated records increases vulnerability because the more data a company retains, the greater the risk that sensitive information might be accessed in a breach. Following a retention schedule helps eliminate unnecessary data, lowering the quantity of sensitive information that hackers might access if a breach occurs.


Aligning Data Deletion with GDPR and Estonian Privacy Obligations


Under GDPR’s data minimization and storage limitation principles, companies are obligated to delete personal data once its intended purpose is fulfilled. This “right to be forgotten” is central to GDPR’s goal of protecting personal data, and non-compliance can lead to heavy fines and regulatory penalties. For example, companies like Allium UPI, managing large volumes of sensitive data, must apply retention schedules to routinely delete records that are no longer required, thus minimizing the likelihood of having outdated, redundant, or obsolete data that could be exploited in a breach.


Information Governance as a Safeguard


Establishing a strong Information Governance (IG) program is essential to ensure compliance with retention schedules and enhance data security. Here are some ways IG supports this goal:


  1. Vital Records Program and Retention Schedules: A robust IG program includes a vital records management approach that identifies critical information and enforces retention schedules. This program helps secure active, necessary records while systematically deleting expired data. Following retention schedules ensures that only essential data remains in storage, reducing data volume and exposure risk.

  2. Employee Training on Data Lifecycle Management: Employees should be trained to follow the organization's data retention policies, including properly disposing of data at the end of its lifecycle. By emphasizing the importance of deleting data per the retention schedule, employees learn to minimize unnecessary storage and reduce potential vulnerabilities.

  3. Incident Preparedness and Regulatory Compliance: An incident response plan also benefits from a retention schedule because, in the event of a breach, it shows regulators that the organization has taken necessary steps to protect data, including regular deletion of unneeded records. Demonstrating adherence to retention schedules can positively impact regulatory scrutiny, showing that the organization meets its data protection responsibilities.


By implementing a clear, defensible retention schedule, organizations like Allium UPI can not only comply with privacy laws but also strengthen their overall security posture. Data deletion per a retention schedule is more than a regulatory check—it’s an essential practice to mitigate risks, protect customer privacy, and maintain trust.


Only by using Information Governance practices, such as adhering to retention schedules, can companies truly secure and responsibly manage sensitive data in today’s privacy-conscious landscape.




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