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Control 1.9: Data Retention and Deletion Policies - Troubleshooting

This playbook provides troubleshooting guidance for Control 1.9.

Common Issues

Issue: Retention Policy Not Applying

Symptoms: Content not being retained as expected

Solutions:

  1. Verify policy is enabled and distributed
  2. Check location scope includes target content
  3. Allow propagation time (up to 7 days)
  4. Verify no conflicting policies
  5. Check for exclusions in policy

Issue: Content Deleted Before Retention End

Symptoms: Items missing before retention period expires

Solutions:

  1. Check for user or admin deletion
  2. Verify retention policy scope
  3. Review if legal hold should apply
  4. Check audit log for deletion events
  5. Verify retention action is "Keep" not just "Delete"

Issue: Disposition Review Not Triggering

Symptoms: Content at retention end not appearing for review

Solutions:

  1. Verify label has disposition review action
  2. Check disposition reviewers are configured
  3. Confirm label is applied to content
  4. Review retention start date calculation
  5. Allow time for processing

Issue: Cannot Delete Content After Retention

Symptoms: Content stuck even after retention period

Solutions:

  1. Check for legal hold on content
  2. Verify disposition review was completed
  3. Check for regulatory record flag
  4. Review if preservation lock is enabled
  5. Contact compliance for manual disposition

Issue: Policy Distribution Failing

Symptoms: Policy shows "Error" or "Pending" status

Solutions:

  1. Check for invalid location references
  2. Verify permissions for policy creation
  3. Review policy for conflicting settings
  4. Check service health dashboard
  5. Retry distribution after 24 hours

Issue: Label Not Available for Selection

Symptoms: Published labels not appearing in locations

Solutions:

  1. Verify label policy includes target location
  2. Allow propagation time (up to 24 hours)
  3. Check user permissions to apply labels
  4. Verify label is published, not draft
  5. Clear browser cache and retry

Symptoms: Content on hold still being deleted

Solutions:

  1. Verify hold is active and scoped correctly
  2. Check hold query filters
  3. Confirm content location matches hold scope
  4. Review if hold was accidentally released
  5. Check for superseding admin actions

SEC 17a-4 WORM Compliance

Important: Standard Microsoft 365 retention policies do not meet SEC 17a-4(f) WORM requirements. For broker-dealers:

  1. Use Preservation Lock for immutable retention
  2. Consider third-party archiving solutions
  3. Obtain written attestation from vendor
  4. Document WORM compliance procedures

Escalation Path

If issues persist:

  1. First tier: Records Management - retention label and policy issues
  2. Second tier: Purview Administrator - distribution and configuration
  3. Third tier: Legal - hold and disposition decisions
  4. Fourth tier: Microsoft Support - platform-level issues

Updated: January 2026 | Version: v1.2