Scan Evidence Retention and Governance: A Production Guide
Retention is two questions, not one, and most programmes answer only the first. The first question is how long the scan output sits in storage. The second question is which artefacts inside the scan output are worth retaining at all, and which ones become regulatory liabilities after the operational window closes. Programmes that pick a single retention duration and apply it uniformly to every artefact either keep too much (privacy and storage exposure on raw scan bodies) or keep too little (audit gaps on summary records auditors actually read). The defensible policy decomposes by artefact class and operates retention against a documented schedule rather than as a storage-pressure release valve.
This guide covers how to set retention per artefact class (scan execution, finding, activity log, raw module output), how compliance frameworks read retention evidence (PCI DSS Requirement 10.5.1, ISO 27001 Annex A 5.33 and 8.10, SOC 2 CC7.1, NIST SP 800-53 AU-11 and SI-12), how privacy regulations layer on top, when to dispose and when to hold, and how internal security, AppSec, vulnerability management, and GRC teams operate retention as part of continuous monitoring rather than as a quarterly spreadsheet exercise.
Retention is per artefact class, not per scan
A single scan produces several distinct artefact classes, and they do not share a retention requirement. Scan executions are run-time records that are large, transient, and useful primarily for the diff between cycles. Findings are lifecycle artefacts that auditors read as evidence of control operation. Activity logs are timestamped chain-of-custody records that bracket every state change. Raw module output, screenshots, and request and response bodies are evidence inside finding records that may contain personal data or business secrets. A retention policy that names only a single duration either over-retains the noisy artefacts or under-retains the audit-relevant ones.
| Artefact class | Typical retention | Trigger to dispose |
|---|---|---|
| Scan execution (run-time record) | 30 to 180 days for the operational window; longer if a framework binds the cycle to evidence. | Age of execution past the operational window, with no open dispute or legal hold. |
| Finding (lifecycle record) | Lifecycle of the finding plus the framework retention window after closure (typically 12 to 36 months). | Closure date plus retention window, with no related open finding, audit hold, or regulatory obligation. |
| Activity log (chain of custody) | 12 months minimum for PCI DSS Requirement 10.5.1; longer for SOC 2 Type II and ISO 27001 surveillance windows. | Plan-based or policy-based age, with audit observation periods accounted for. |
| Raw module output and bodies | Operational window only; redact at the point of capture for personal data. | Operational window age plus privacy review. |
| Scan report (final delivered artefact) | Audit window per framework, plus contractual retention if the report was delivered to a client or auditor. | End of the longest applicable retention obligation. |
The shape of the policy is decomposition: short retention on the noisiest, most privacy-exposed artefacts, and longer retention on the durable lifecycle records auditors read. Programmes that set 12 months on every artefact class store noise and create privacy risk; programmes that set 30 days on every artefact class lose audit evidence. The scanner output deduplication guide covers the upstream discipline that keeps the retained record clean across cycles.
Calendar retention and trigger-based retention
Retention has to operate on two axes at once. Calendar retention answers the steady-state question: how long does each artefact class sit in storage by default. Trigger retention answers the lifecycle question: when does an event change the retention obligation for a specific artefact ahead of the calendar bound. Policies that watch only the calendar miss the trigger events that change retention; policies that watch only triggers miss the calendar floor frameworks expect.
Finding closure
A finding closure does not start retention; it starts the retention countdown for the finding record after the operational window. The finding evidence is durable from creation; closure changes the retention bound from open-ended (while the finding is active) to closure date plus the framework retention window.
Audit observation period close
A SOC 2 Type II or ISO 27001 surveillance window closes. The records inside the window have to be retained through the assessor review and any subsequent year-on comparison. The retention policy should not dispose records that span the observation window during the assessor review.
Legal hold or regulatory investigation
Litigation, regulatory inquiry, breach investigation, or active incident response pauses disposal indefinitely. The hold is recorded on the affected scope (a workspace, an engagement, a finding, a target), disposal stops for that scope, and disposal resumes on the original schedule when the hold is released.
Privacy review against personal data
A finding or scan execution is identified as containing personal data. The retention bound shifts from the security retention period to the lower of the security retention and the privacy retention justified under the regulation (GDPR Article 5(1)(e), CCPA, UK GDPR). Disposal happens at the lower bound.9,10
Customer or engagement end
The customer relationship ends or the engagement closes. The retention obligation does not end with the engagement; the records remain audit-relevant for the framework window. The policy names whether records hand over, retain in place, or dispose selectively at engagement close.
CISA KEV-driven retrospective
A vulnerability is added to the CISA Known Exploited Vulnerabilities catalogue and the team needs to retrospectively confirm whether a past scan covered the affected service. Retention has to extend far enough back for the lookup to succeed; programmes that purge scan executions on 30-day windows often cannot answer the retrospective.11
How compliance frameworks read scan retention
Auditors do not read retention as a duration claim on a policy document. They read retention as the count of records inside the audit observation period and the evidence that the records survived through the assessor review. The framework expectations below set the floor; programmes justify higher retention on a risk basis when assets warrant it.
- PCI DSS v4.0 Requirement 10.5.1 expects audit log history to be retained for at least 12 months, with at least the most recent three months immediately available. Requirement 11.3 requires internal and external scans at least quarterly and after significant change; the evidence has to show the scans operated across the audit window, which depends on retention spanning the window.1
- ISO 27001:2022 Annex A 5.33 (records protection) expects records to be protected from loss, destruction, falsification, unauthorised access, and unauthorised release for the period justified by legal, regulatory, contractual, and business requirements.2
- ISO 27001:2022 Annex A 8.10 (information deletion) expects information to be deleted when no longer required, in accordance with the retention policy and applicable regulations. Disposal is a controlled activity, not a passive expiration of storage.3
- ISO 27001:2022 Annex A 8.15 (logging) expects event logs to be produced, stored, protected, and analysed. The standard does not name a single retention period; the period is justified against the risk assessment and the wider records policy.4
- SOC 2 Trust Services Criteria CC7.1expects ongoing detection of new vulnerabilities. The audit observation period is typically 6 to 12 months, and retention has to span the period plus the assessor review window.5
- NIST SP 800-53 control AU-11 (audit record retention) expects retention defined by mission, regulatory, and operational requirements. Control SI-12 (information management and retention) extends the retention discipline to organisational records more broadly.6
- NIST SP 800-92 (computer security log management) names the operational drivers for retention: incident detection, forensic analysis, regulatory compliance, internal investigation, and trend analysis. Retention duration is the lowest common denominator across the drivers.7
The shared pattern across these frameworks is that retention is operational, not ceremonial. A retention policy that names a duration and produces no evidence the records persisted across the window satisfies the documentation bar and fails the operating-effectiveness bar. Programmes that retain records on the live engagement and produce evidence as a side effect of operation pass the audit read; programmes that backfill at audit week pass on date stamp and fail on retention operation.
Disposal as a controlled activity
Disposal is the deliberate end of retention and the deletion of records that are no longer required. Three rules govern disposal: it happens against a documented schedule, not by accident or storage pressure; it does not delete records under legal hold; and it is recorded as an event so the audit trail shows the disposal happened against the schedule rather than as data loss.
Documented schedule
The disposal schedule names the artefact class, the retention period, the trigger event, and the disposal method. Disposal that runs without a schedule produces evidence the assessor reads as data loss rather than as policy operation.
Disposal method
The method is named in the policy and follows the framework guidance. NIST SP 800-88 covers media sanitisation patterns (clear, purge, destroy) for storage that holds the records. For database-resident records, secure deletion through the storage layer plus cryptographic erasure of any stored secrets is the defensible pattern.12
Legal hold
A hold is recorded on the affected scope (workspace, engagement, finding, target). Disposal stops for that scope until the hold is released. The hold record names who placed the hold, the date, the reason class (litigation, regulatory inquiry, incident response), and the release condition.
Disposal record
Each disposal event is recorded with the artefact class, the count, the date, the schedule rule that triggered it, and the user or system actor. The record is the evidence the policy operated; absence of a disposal record is read as either non-compliance with the policy or data loss.
Retention and privacy regulations
Scan output can include personal data when authenticated scans capture session details, when external scans pick up personal information in metadata or content, or when finding evidence captures end-user data inadvertently. Privacy regulations layer retention obligations on top of security retention.
- GDPR Article 5(1)(e) (storage limitation) requires personal data to be retained no longer than necessary for the purpose; the scan retention period for personal data has to be justified against the security purpose and reviewed when the purpose changes.9
- UK GDPR storage limitation follows the same principle, with the UK Information Commissioner expecting documented justification for the retention period and a review cycle.10
- Subject access and deletion requests can reach scan artefacts. The retention model has to be searchable so a deletion request can identify and dispose the relevant records inside the regulatory response window.
- Sensitive data classes (health, financial, government identifiers) carry stricter retention rules under sector regulation. HIPAA, PCI DSS, and sector-specific regulators set retention windows that override the general rule for the data classes they cover.
Three operational practices keep scan retention compatible with privacy regulation. Minimise capture: configure the scanner so personal data is not collected unless the test requires it. Redact at capture: scrub personal data in finding evidence at the point of creation rather than at retention close. Document the retention period and the justification per artefact class so subject access and deletion requests can be answered against the same record the security retention operates on.
Operational checklist for a defensible scan retention policy
At policy design
- The policy names artefact classes, retention durations, triggers, disposal methods, and disposal records.
- Retention is justified against the framework floors that apply to each artefact class.
- Privacy retention bounds are layered on top of security retention bounds.
- Legal hold procedures, roles, and release conditions are documented.
- The policy names the data owner, retention administrator, and audit liaison.
At scan creation and execution
- The scan configuration minimises personal data capture where the test does not require it.
- Findings are written to the engagement record so the lifecycle is auditable.
- Activity log entries record the scan execution with timestamp and actor.
- Sensitive evidence (request bodies, screenshots) is scoped to the finding it supports rather than retained as standalone artefacts.
During the retention window
- Records are protected by access controls scoped to the roles that need them.
- Audit observation periods are tracked so records are not disposed during a sampling window.
- Legal holds pause disposal on the affected scope and the hold record persists.
- Subject access and deletion requests are served against the same record the audit reads.
At disposal
- Disposal runs against the documented schedule, not against storage pressure.
- Disposal events are recorded with artefact class, count, date, and triggering rule.
- Disposal does not touch records under legal hold, including dependent records (a finding under hold blocks disposal of the supporting scan executions).
- The disposal method follows the policy and the framework guidance for the storage tier.
For internal security and vulnerability management teams
Internal security teams and vulnerability management teams operate retention as part of continuous monitoring, not as an annual policy refresh. The disciplines that hold up under audit and under remediation pressure are the same: per-artefact retention, trigger-based overrides on top, legal hold as a first-class lifecycle state, and disposal as a controlled activity recorded in the same audit trail the operations run on.
- Set retention per artefact class rather than as a blanket policy across all scan output.
- Wire the retention schedule into the storage layer so disposal is automatic and recorded, not manual at audit week.
- Hold the chain-of-custody record (creation, modification, closure, disposal) on the same activity log the operators read.
- Track legal hold as a state on the affected scope so disposal jobs honour it without manual intervention.
- Review the retention policy whenever a framework, regulation, or business obligation changes the floor.
For internal security teams, vulnerability management teams, AppSec teams, and GRC and compliance teams, the operating commitment is to keep retention visible on the same record the audit reads, with disposal recorded as a controlled event rather than as a storage housekeeping job. The audit evidence half-life research covers how retention duration interacts with evidence quality across the audit observation window, and the audit evidence retention and disposal workflow covers the broader retention discipline that scan evidence is one input into.
How SecPortal handles scan evidence retention and governance
SecPortal retains scan executions and code scan executions with a configurable retention window, retains findings independently of scan execution lifetime, and records every state change in the activity log so the chain of custody persists through retention and disposal.
Scan execution retention
Scan executions, scan jobs, and code scan executions are retained for the window set by the `SCAN_RETENTION_DAYS` environment variable (default 90 days). A weekly cron (Sunday 04:00 UTC) runs the `purge-old-scans` job, which deletes completed and failed records older than the cutoff. The schedule is documented and operates automatically rather than as a manual task. The external scanning feature, authenticated scanning feature, and code scanning feature cover the scan classes that fall under the retention window.
Findings persist through scan execution disposal
Findings are retained independently of scan execution retention. Closing or purging a scan execution does not remove the findings derived from it; the lifecycle record remains intact through closure and audit. The findings management feature holds the finding lifecycle, evidence, and closure record.
Activity log retention by plan
The activity log records every finding, engagement, scan, document, comment, invoice, and team change with a timestamp and acting user. Retention is plan-based: 30 days on Starter, 90 days on Pro, 365 days on Team. A daily cron (03:00 UTC) runs the `cleanup-activities` job, which removes activity records older than the workspace plan retention. The activity log feature covers the chain-of-custody record auditors read.
Compliance tracking maps retained evidence
Compliance tracking maps findings and controls to ISO 27001, SOC 2, Cyber Essentials, PCI DSS, and NIST so the retained evidence aligns to the framework view assessors read. The compliance tracking feature covers the framework crosswalks the retained record feeds.
Storage controls during retention
Encrypted credential storage uses AES-256-GCM, MFA enforcement promotes sessions to AAL2 before sensitive operations, and RBAC scopes access to the retention actions per role. The encrypted credential storage feature and multi-factor authentication feature bracket the retention model so records are protected during the window.
The schedule, the runs, and the disposal events land on the same record the operators run on, so the audit view reads from the live record rather than from a backfilled evidence pack. The continuous monitoring feature covers the schedule cadence the retention model bookends.
Related scanner discipline
Retention depends on the upstream and downstream disciplines that bracket it. The pages below cover the surrounding decisions.
- Scan scheduling and baseline cadence covers the cadence the retention window has to span end to end.
- Scan baseline and trend comparison covers how the retained scan record feeds the multi-cycle trend leadership and audit read across the observation window.
- Scanner output deduplication covers the upstream merge discipline that keeps the retained record clean across scans and tools.
- Scanner coverage and limits covers what each scanner class can and cannot reach so retained evidence does not imply coverage that did not happen.
- Scanner output formats covers the formats retained evidence can be exported in for handover, audit, or legal hold.
- Scanner credential rotation and lifecycle covers the credential lifecycle that is retained alongside the scan record so the credential state at scan time is reproducible.
- Scanner evidence chain from scan execution to closed finding covers the seven evidence layers retention preserves end to end so the audit read of any closed finding traces back to the scan that produced it.
- Audit evidence retention and disposal workflow covers the broader audit retention discipline that scan evidence is one input into.
- Audit evidence retention policy template covers the policy framework retention is documented under.
- Audit evidence tracker covers the tracking artefact retained evidence is logged in.
- Cybersecurity risk assessment guide covers the risk view that retention duration is justified against.
For the wider operating model retention plugs into, the audit evidence half-life research covers how evidence ages between assessments, and the continuous control monitoring cadence research covers how the cadence and retention combine to produce the operating-effectiveness evidence auditors read.
Scope and limitations of this guide
Scan evidence retention is a programme discipline, not a configuration setting. No retention duration makes the underlying scan output more useful than it was at capture; no disposal schedule replaces the access controls that protect the records during retention. The retention question is which artefacts are worth keeping, for how long, and under what conditions disposal is allowed. The answer is per artefact class, per framework floor, per privacy obligation, and per legal hold state.
Retention claims that depend on a single duration almost always overstate the uniformity of the data inside the scan output. Retention claims that decompose by artefact, that pair the schedule with documented disposal, that hold legal hold as a first-class lifecycle state, and that record the disposal events on the same activity log the operations run on are the claims that survive the audit and the privacy review.
Frequently Asked Questions
Sources
- PCI Security Standards Council, PCI DSS v4.0 (Requirement 10.5.1, 11.3, 11.4, 12.10.1)
- ISO/IEC, ISO 27001:2022 Annex A 5.33 Records Protection
- ISO/IEC, ISO 27001:2022 Annex A 8.10 Information Deletion
- ISO/IEC, ISO 27001:2022 Annex A 8.15 Logging
- AICPA, SOC 2 Trust Services Criteria CC7.1 (System Operations)
- NIST, SP 800-53 Rev. 5 (AU-11 Audit Record Retention, SI-12 Information Management and Retention)
- NIST, SP 800-92 Guide to Computer Security Log Management
- NIST, SP 800-115 Technical Guide to Information Security Testing and Assessment
- European Union, GDPR Article 5(1)(e) Storage Limitation
- UK Information Commissioner, GDPR Storage Limitation Guidance
- CISA, Binding Operational Directive 22-01 (Known Exploited Vulnerabilities)
- NIST, SP 800-88 Rev. 1 Guidelines for Media Sanitization
- SecPortal, Continuous Monitoring Feature
- SecPortal, Activity Log and Workspace Audit Trail
- SecPortal, Findings Management Feature
- SecPortal, Compliance Tracking Feature
- SecPortal Research, Audit Evidence Half-Life
Run retention on the live engagement record, not on a quarterly spreadsheet
SecPortal retains scan executions on a configurable cadence, retains findings through closure and audit, records every state change on the activity log, and maps the retained evidence to the framework view auditors read so retention operates as evidence rather than as a stack of static reports.