Control area

AI use and data retention: who owns it on each service model

What is sent to an AI model or kept in a service, for how long, and for what purpose it may be used. Your prompts, outputs and retention are yours; the provider's use of them for training is set by its terms.

The split by service model

Service model	Owner	Why, and the clause
Infrastructure as a service	yours	What data goes into the service, for what purpose and how long it is kept is yours to decide and delete; the provider stores what you give it. ISO/IEC 27017 CLD.8.1.5
Platform as a service	yours	What data goes into the service, for what purpose and how long it is kept is yours to decide and delete; the provider stores what you give it. ISO/IEC 27017 CLD.8.1.5
Software as a service	shared	Retention and purpose settings in the service are yours to choose; how the provider itself retains and uses what you send is set by its terms, which you must read. ISO/IEC 27018 A.3.1
Serverless functions and event services	yours	What data goes into the service, for what purpose and how long it is kept is yours to decide and delete; the provider stores what you give it. ISO/IEC 27017 CLD.8.1.5
Hosted AI models and AI platforms	shared	Retention and purpose settings in the service are yours to choose; how the provider itself retains and uses what you send is set by its terms, which you must read. ISO/IEC 27018 A.3.1

Services that move the line

Hosted large language model API: yours Your prompts, the outputs you keep and how long you keep them are yours to govern and delete; whether the provider may use them for training is set by its terms, which you must read (named, not quoted).
AI assistant in a SaaS suite: shared The assistant reads what your users can already reach; which content it may use, and the retention setting, are yours to choose, while the provider's own use of prompts is set by its terms.

The clauses each framework attaches

9 quoted

Framework	Clause
Cloud Controls Matrix v4.0.1	CCM-DSP-12 Limitation of Purpose in Personal Data Processing · CCM-DSP-16 Data Retention and Deletion
ISO/IEC 27017:2015	ISO/IEC 27017 CLD.8.1.5 Removal of cloud service customer assets
ISO/IEC 27018:2019	ISO/IEC 27018 A.3.1 Public cloud PII processor's purpose · ISO/IEC 27018 A.3.2 Public cloud PII processor's commercial use
SOC 2 Trust Services Criteria	SOC 2 P4.2 Personal information is retained for only as long as needed
ISO/IEC 27001:2022 Annex A	ISO/IEC 27001 8.10 Information deletion
CMMC 2.0	CMMC AC.L2-3.1.22 Control Public Information
C5 cloud criteria catalogue	C5-PI-03 Secure deletion of data

CCM-DSP-12 Limitation of Purpose in Personal Data Processing

Confine personal data processing to the purposes declared to the data subject and permitted by applicable law, and be able to demonstrate that limit.

What an assessor asks to see:

The declared purposes per processing activity and the notice given to data subjects
Controls that prevent processing outside the declared purpose
Evaluation evidence such as a review of actual processing against declared purpose
Records of new purposes and how consent or legal basis was re-established

Where it usually falls short:

Data collected for one purpose reused for analytics without re-establishing a basis
Declared purposes written so broadly they permit anything
No review comparing actual processing to declared purpose

Source: Cloud Controls Matrix v4.0.1

CCM-DSP-16 Data Retention and Deletion

Manage data retention, archiving and deletion against business requirements and applicable law, so data is neither kept longer nor destroyed sooner than allowed.

What an assessor asks to see:

The retention schedule by data type with the requirement behind each period
Evidence retention periods are enforced technically
Deletion records at end of retention
Legal hold procedure and its interaction with deletion

Where it usually falls short:

Retention schedule published with no technical enforcement
Data retained indefinitely because deletion was never built
Legal hold not accounted for, so data under hold is deleted

Source: Cloud Controls Matrix v4.0.1

ISO/IEC 27017 CLD.8.1.5 Removal of cloud service customer assets

Assets of the cloud service customer that are on the cloud service provider's premises are to be removed, and returned where necessary, in a timely manner when the cloud service agreement ends. The provider should describe how customer assets are returned and deleted at termination, in what form and within what time; the customer should plan for termination from the start, including retrieval of its data in a usable format and confirmation of deletion.

What an assessor asks to see:

Provider termination and data return procedure with timescales
Customer exit plan for the cloud service
Confirmation of deletion after termination

Where it usually falls short:

Data return window shorter than the customer's migration takes
Provider deletes customer data with no confirmation, or keeps it in backups indefinitely

Source: ISO/IEC 27017:2015

ISO/IEC 27018 A.3.1 Public cloud PII processor's purpose

PII to be processed under a contract should not be processed for any purpose independent of the instructions of the cloud service customer; the processor acts only on the customer's documented instructions and does not determine purposes of its own for customer PII.

What an assessor asks to see:

Contract clause restricting processing to customer instructions
Internal rule and controls preventing secondary use
Evidence of instruction-based processing

Where it usually falls short:

Analytics or product improvement run on customer PII without instruction
Instructions accepted informally with no record

Source: ISO/IEC 27018:2019

ISO/IEC 27018 A.3.2 Public cloud PII processor's commercial use

PII processed under a contract should not be used by the processor for the purposes of marketing and advertising without express consent, and such consent should not be a condition of receiving the service. This control is an addition to the general control in A.3.1 and is not intended to override it.

What an assessor asks to see:

Policy prohibiting marketing use of customer PII
Consent mechanism, if any, separate from the service terms

Where it usually falls short:

Marketing consent bundled into the service agreement
Usage data derived from customer PII used to target advertising

Source: ISO/IEC 27018:2019

SOC 2 P4.2 Personal information is retained for only as long as needed

Retains personal information consistent with the entity's objectives related to privacy

What an assessor asks to see:

The retention schedule for personal information, with the period per data type and its legal or business basis
Evidence of enforcement, such as automated deletion jobs, purge reports or records of manual disposal
Evidence retention covers all copies, including backups, archives, replicas, exports and third party held data
Records of legal holds or other justified exceptions, with approval and expiry
Evidence of monitoring showing personal information beyond its retention period is identified and removed

Where it usually falls short:

Retention schedule documented with no enforcement anywhere, so nothing is deleted
Deletion performed in the production database while backups, data warehouses and exports retain the data
Legal holds applied and never released, becoming permanent retention by default
No monitoring, so overdue data is only discovered during an audit or an incident

Source: SOC 2 Trust Services Criteria

ISO/IEC 27001 8.10 Information deletion

Delete information in systems, devices and media when no longer required.

What an assessor asks to see:

Deletion policy
Media disposal log
System deletion audit
Data retention schedule

Where it usually falls short:

Retaining data beyond approved period
No evidence of secure erase verification
Policies not aligned with actual practice
Incomplete media disposal records

Source: ISO/IEC 27001:2022 Annex A

CMMC AC.L2-3.1.22 Control Public Information Level 1 and 2

Control CUI that is posted to or processed on publicly accessible systems so CUI is not released to the public.

What an assessor asks to see:

Review and approval process for content published publicly
Designated reviewer authorizations and review records
Evidence of periodic scanning of public sites for CUI

Where it usually falls short:

Publication approval informal or undocumented
No periodic check of already published content
Public facing systems not identified as in scope

Source: CMMC 2.0

C5-PI-03 Secure deletion of data

Erase customer data at the end of the contractual relationship in line with the agreed terms, covering the customer environment, metadata and backup copies, using methods that defeat recovery by forensic means.

What an assessor asks to see:

Erasure procedure spanning the live environment, metadata stores and backup media
Completion confirmation issued for a terminated customer within the agreed period
Technical description of the wiping or key destruction method relied upon
Backup retention schedule showing when residual copies finally expire

Where it usually falls short:

Live data removed while backup copies persist to the end of an unchanged retention cycle
Metadata, audit trails and derived indexes retained after the content itself is gone
Removal limited to deleting pointers, leaving content readable from the underlying media

Source: C5 cloud criteria catalogue