Data retention and right to be forgotten

Omada Identity Cloud handles historical data in the Omada Data Warehouse (ODW), which powers Analytics, and database backups separately. Changing the ODW retention period removes older history from the data warehouse, but it does not change backups that have already been taken.

This page explains what happens to your data when you shorten the retention period, how to anonymize data to fulfill a right to be forgotten request, and how long data can remain in backups.

ODW history retention

When you change the ODW retention period to a shorter duration, the cleanup process deletes data from the data warehouse that is older than the new retention limit. For example, if you reduce the retention period from five years to two years, the cleanup process removes the warehouse history that is older than two years.

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The cleanup process does not remove the latest version of an object. An object that is older than the retention period is not necessarily deleted from ODW, because its latest version is kept.

Right to be forgotten and anonymization

Omada Identity generally stores employee data rather than consumer data. If you need to anonymize an identity's data, for example to fulfill a right to be forgotten request under the EU General Data Protection Regulation (GDPR), you can use one of the following options:

• If Horizons is not enabled in your environment, use the Anonymization of objects import profile. For more information, see Anonymization of objects.
• If Horizons is enabled in your environment, the Anonymization of objects import profile is not supported, and there is no automated anonymization process. Contact Omada Support to request anonymization, and include the details of the environment where the data is stored. The Omada team assesses your request and prepares a custom anonymization script for your environment.

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Anonymization changes data in the live databases only. The original, non-anonymized data can remain in existing backups until those backups expire. For more information, see Backup retention.

This section describes how anonymization works in Omada Identity Cloud. It does not determine your legal obligations under the GDPR or other regulations. To find out what your organization must do to fulfill a right to be forgotten request, consult your legal or compliance team.

Backup retention

Backups are independent of the ODW retention settings. When you shorten the ODW retention period, or when data is deleted or anonymized, the change applies to the live data warehouse only. Backups that have already been taken cannot be modified, so the data remains in them until they expire under the backup policy.

The following backup policy applies to Azure SQL databases in production environments, both geo-redundant and non-geo-redundant:

Backup type	Retention or frequency
Point-in-time restore (PITR)	Retained for 35 days.
Differential backups	Taken every 12 hours.
Weekly long-term retention (LTR)	Retained for 52 weeks.
Monthly long-term retention (LTR)	Retained for 12 months.
Yearly long-term retention (LTR)	The backup from week 1 is retained for 5 years.

Depending on which backup contains the data and when that backup expires, data that has been deleted or anonymized in the live databases can remain in backups, in its original form, for up to five years.

Backup policies can vary between environments and can change over time. To confirm the backup policy that applies to your environment, contact Omada Support.

Frequently asked questions (FAQ)

• If I reduce the ODW retention period, is older history removed?

  Yes. The cleanup process removes data that is older than the new retention limit.

• Is every object older than the retention period deleted?

  No. The cleanup process keeps the latest version of each object.

• Can I anonymize data automatically?

  Only with the Anonymization of objects import profile, which is not supported when Horizons is enabled. Otherwise, contact Omada Support.

• Does reducing the ODW retention period change backup retention?

  No. Existing backups are kept until they expire.

• How long can data remain in backups?

  Up to five years, under the yearly long-term retention policy. To confirm the backup policy for your environment, contact Omada Support.