3 Mar 2026 · PDPA
Retention windows that survive a warehouse copy
Thailand’s PDPA does not care that your privacy page says ninety days if the BI extract has no clock. Analytics stewards need evidence, not slogans.
We keep meeting teams whose legal page is tidy and whose warehouse is sentimental. Product analytics tables accrue “just in case” history. An intern exports a CSV before Songkran. A partner feed refreshes without a deletion clause. When counsel asks for evidence of a retention window, the analytics lead opens Looker and hopes.
Cloudcacheline teaches retention as a clock attached to a copy, not as a sentence attached to a brand. This is operational teaching for analytics teams in Thailand. It is not legal advice and it is not a substitute for your DPO.
One stream, many clocks
Take a single event family — say search_submitted. The primary warehouse table might honestly drop rows after 90 days. The aggregate table used for year-on-year charts might keep counts without identifiers, which is a different decision. The laptop CSV still has identifiers. The reverse-ETL audience in the ESP still has identifiers. If you only clock the first table, you have theatre.
In the Retention Clocks under PDPA lab we force a three-column list: copy name, owner, deletion or anonymisation date. Empty owner is not allowed. “Shared analytics folder” is not an owner.
What “survive a copy” means
A window survives if a new analyst, six months later, can answer three questions without calling the person who left: which copies exist, when each is due, and what job runs or human action executes the due date. If the answer is “we trust the vendor,” write the vendor’s retention term on the same page. Vendor silence is a risk, not a policy.
Rayong checklist we actually use
Inventory copies before arguing about days. Separate identified rows from aggregates. Name the human who can drop a table. Put the laptop problem in writing — it is usually the embarrassing one. Show the list to counsel; do not ask analytics to guess what PDPA “really wants” in a vacuum.
If you need the longer path, including consent flags that travel with the same events, see The Analytics Data Contract. If you only have a day, ask for the Governance Desk.