Your retention policy probably defines category timelines precisely: contracts held for 7 years, employee records for 5 years after departure, personal data for as long as lawful processing continues. The policy is good. The problem is that a policy doesn't execute itself, and most organizations have no operational process to make sure it actually runs.
The gap between policy and practice is almost always an operational failure, not a legal one. The legal team wrote a defensible policy. Nobody designed the monthly review process that checks which data is due for disposal, generates evidence of that review, and produces a traceable record when a regulator asks what happened to a specific category six months ago.
Spreadsheet-based retention management has three failure modes, and they're entirely predictable. Ownership fragmentation: who checks which category this month? Version conflicts: which spreadsheet is the current retention schedule? Missing evidence: the review happened, but there's no record of who authorized the disposal or what criteria were applied. If you've been relying on a spreadsheet, you've likely hit all three.
A scheduled Flow opens automatically on the first business day of each month. Each data category becomes a discrete task assigned to its owner: review what records are due for disposal, confirm the disposition decision, attach the disposal authorization, and mark it complete. The run doesn't close until every task is resolved, no exceptions, no workarounds.
For regulated data categories, personal data under LGPD or GDPR, financial records under fiscal retention law, health data under sector-specific windows, the Flow requires a legal review approval gate before any disposal action proceeds. No unilateral deletion of regulated data outside a documented, authorized decision.
After each completed monthly run, every question a data protection authority would ask is answerable: which category was reviewed, on which date, who made the disposition decision, what authorization was attached, whether any exceptions were escalated. The evidence is not in someone's inbox. It's in the run.
Twelve months of completed retention runs produces a compliance record that is demonstrably stronger than any policy document alone. It shows not just what the policy says, it shows the precise sequence of how and when it was executed, month after month.
