France: French Data Privacy Authority Published New Guidelines on Document Retention

On 2 April 2026, the French Data Privacy Authority (CNIL) published new guidelines on how long companies can keep HR documentation.

All HR professionals need to know how long they must or can keep HR documentation. Too short and they can find themselves in difficult situations, such as a dispute; too long and they can incur financial sanctions under data privacy regulation.

CNIL’s new guidelines lists all common types of HR documentation, sets out the duration for which companies are required to keep such HR documentation by law, and explains how and where to store such information electronically.

For example, the CVs of candidates who are not hired can be stored for 2 years in the production database but up to 5 years in intermediate storage so as to be able to be produced in case of future discrimination litigation.

Key Action Points for Human Resources and In-House Counsel

Check your HR documentation retention policy to ensure compliance with legal requirements and data privacy regulations.