Direct answer
Data may be retained temporarily while deletion or machine unlearning is pending, but it must not remain available for ordinary decision use. The restriction record defines the data, person, purpose, system, duration, owner and release condition. Enforce the rule technically at the data layer and at retrieval, feature-store, vector-record, memory, tool, export, training and model-serving points. If no safe outcome can be produced for a high-impact decision, stop the action or refer it for authorised human review. Ordinary use resumes only through a verified release gate.
In plain language
A potentially spoiled ingredient may remain in the kitchen, but a 'held for inspection' label must stop it from being added to a meal. The restriction must work not only on the box but in every recipe that could use the ingredient.
Why this matters
Deletion may take days or longer. If the data keeps producing new decisions in the meantime, further harm may be added and the correction population will grow.
Do not confuse
- Temporary retention is not permission for ordinary decision or training use.
- Restriction stops specified uses; deletion aims to end the data's lifecycle.
- Quarantine separates an object; a non-use rule blocks every relevant path of use.
- Where no safe result is possible, stopping prevents harmful default use; human review may provide a controlled alternative.
- A release gate requires evidenced conditions to be met, not merely the passage of time.
What should you do?
- Record the restricted data, person, purpose, systems, reason, owner, start and review date.
- Inventory decision, retrieval, vector-record, memory, training, export, tool and model-serving paths.
- Enforce the non-use rule technically at every execution point rather than through a label alone.
- If safe data is unavailable for a high-impact outcome, stop the action or refer it for authorised human review.
- Block derived features, caches, profiles and downstream copies of the restricted data as well.
- Track blocked uses and any use that occurs in error through incident records and alerts.
- Restore ordinary use only after root cause, deletion or unlearning, and release evidence have been verified.
How do you audit it?
- Are the restricted object, reason, scope, owner and times explicit?
- Are all decision and data-use paths in the inventory?
- Is the restriction actually enforced across retrieval, training, memory, export and tool layers?
- Does prohibited use continue through derived data or a cache?
- Is there a safe stop or human alternative for a high-impact decision?
- Are violations detected and handled through the incident process?
- Does expiry trigger automatic use, or an evidence-based release review?
Limit
It may be impossible to stop every use, and shutting down every process may itself cause loss of service or rights. The restriction should be proportionate to risk, purpose, legal basis and safe alternatives, and must not become a new adverse signal against the person.
Remember in one sentence
Data may be retained while deletion is pending; ordinary use may not continue.
Sources for this record
- S26NIST SP 800-53 Rev. 5, *Security and Privacy Controls*Standard
- S38NIST AI 600-1, *Artificial Intelligence Risk Management Framework: Generative Artificial Intelligence Profile*Voluntary standards-oriented institutional guidance
- S39NIST AI 100-2 E2025, *Adversarial Machine Learning: A Taxonomy and Terminology of Attacks and Mitigations*Voluntary standards-oriented institutional guidance
- S44NIST, *AI Risk Management Framework Playbook* and AI RMF CoreVoluntary implementation guidance
- S48European Union, Regulation (EU) 2016/679 — *General Data Protection Regulation*Legislation
- S49Turkish Personal Data Protection Authority, *Personal Data Protection Law No. 6698*Official authority and legislation
- S64Turkish Personal Data Protection Authority, *Regulation on the Deletion, Destruction or Anonymisation of Personal Data*Official authority and legislation

