{
  "id": "POL-115",
  "slug": "pol-115",
  "title": "Children's data needs a published retention policy",
  "statement": "The privacy policy must publish a written data-retention policy for children's data, with the purpose, the justification and the deletion timeframe.",
  "rationale": "The 2025 COPPA amendments require the retention policy to be published rather than merely held, which is a change most businesses have not noticed. The substance matters as much as the publication: a retention rule with no deletion timeframe is a commitment to keep a child's data indefinitely, stated in public.",
  "layer": "POLICY_PAGE",
  "layerSlug": "policy-page",
  "object": "privacy policy body",
  "severity": "HIGH",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "TERMINAL_POLICY",
  "artifact": "privacy_policy",
  "authorities": [
    "FTC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Add the retention rule to the children's section: what is kept, why, and for how long. Done when the section states a period rather than a condition.",
  "example": "Where we learn that a subscriber is under 13 we delete the number and its consent record within 30 days, keeping only the fact of the deletion.",
  "notes": "Conditional on children's data being in scope, which no applicability dimension expresses; the criteria pass immediately where it is not.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/policy-page/pol-115/",
  "markdown": "https://ekas.io/rules/10dlc/policy-page/pol-115.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}