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Glossary/GLOSSARY

Exemption

An exemption is a broker's determination that a record matched by a deletion request will be retained rather than deleted because a law permits or requires keeping it, reported back to DROP as status code 2.

In plain terms

Deletion rights are not absolute. Another obligation, a retention rule, a legal hold, or an active dispute can require you to keep information a consumer asked you to delete. DROP has one code for all of those, status 2, and it carries no reason field. There is no separate code for a legal hold. The platform records that the record was exempted. It does not record why, and it does not assess whether you were right to claim it.

What it means for a registered broker

The determination is yours, and it is a legal judgment rather than a matching outcome. Software can show you which records matched. It cannot tell you which of them you are entitled to keep. Decide each one, or each clearly defined batch, deliberately, and write the reason into your own audit record even though DROP has nowhere to put it. That reason is what you would produce if the determination is questioned later. Default to nothing. An exemption applied out of habit is the one that will be hard to explain.