Configuring SAP ILM for GDPR and CCPA Compliance: A Comprehensive Guide

In today’s regulatory climate, compliance with GDPR (General Data Protection Regulation) and CCPA (California Consumer Privacy Act) is no longer optional—it’s essential. SAP Information Lifecycle Management (ILM) provides the tools to handle retention, blocking, and deletion of personal data across your SAP landscape. This article walks you through a step-by-step configuration blueprint to get your ILM setup ready for GDPR and CCPA.

1. Lay the Foundation: Governance & Scope

Every ILM journey starts with governance. Define the project team, roles, and responsibilities. Clarify which systems and objects fall under ILM—structured data (tables), unstructured content (attachments), and archived files. Establish clear ownership of retention policies and blocking decisions.

2. Enable Technical Prerequisites

To ensure a smooth setup, follow these steps:

• Activate ILM Business Functions: ILM, ILM_BLOCKING, BUPA_ILM_BF, and ERP_CVP_ILM_1 (plus industry-specific add-ons if needed).

• System Setup: Configure RFC connections, services, and support packages.

• Authorizations: Restrict access to blocked data by defining authorization groups. This ensures only auditors or authorized roles can view restricted information.

  
  

3. Configure the ILM Store

For compliant retention and deletion, you need a BC-ILM certified WebDAV store.

• Create an RFC destination (SM59).

• Register the store in ILMSTOREADM.

• Maintain the ILM Store Service in SARA. This ensures archive files and attachments are stored securely under ILM retention control.

  
  

4. Define Audit Areas & Policies

Audit areas act as the “reason codes” for retention.

• Use ILMARA to confirm relevant areas such as BUPA_DP (blocking personal data), ARCHIVING (residence/retention), and HCM_DP (HR data).

• Build policies in IRMPOL with residence and retention rules. For example, customer data in ERP_CUST must be blocked after 3 years of inactivity and destroyed after 7 years.

• Optionally, leverage IRMRULE to set up complex controller rules (with periods, authorization groups, and store assignments).

  
  

5. End-of-Purpose Check & Blocking

When the residence period ends, ILM runs an End-of-Purpose (EoP) check:

1. Confirm no open transactions exist.

2. Verify rules in BUPA_DP are satisfied.

3. Block the record, preventing normal access.

   
   

Blocked data is visible only to users with special authorization—fulfilling GDPR’s “restriction of processing” requirement.

6. Data Destruction

SAP ILM supports destruction of data at multiple levels:

• Database records: via ILM destruction objects.

• Archived files: through SARA and ILM Store enforcement.

• Attachments & print lists: using ILM_DESTRUCTION.

  
  

Important: Only archive files in a BC-ILM store can be destroyed under compliance control.

7. Legal Holds

Sometimes data must be preserved—even beyond retention periods—due to litigation or audits.

• Apply a legal hold that suspends destruction across DB, ArchiveLink, and archive files.

• Schedule propagation jobs (ARC_LHM_PROPAGATE_LEGAL_HOLD) so the ILM store enforces the hold at the storage level.

  
  

8. Testing & Simulation

Before you go live, it’s crucial to validate your setup:

• Run CHECK_ILM_OBJECT_STATICALLY to validate configuration.

• Use ILMSIM to simulate rule evaluation.

• Perform pilot runs in QA using SARA and ILM_DESTRUCTION, verifying expiry dates and audit logs.

  
  

9. Ongoing Operations

Once live, automate:

• EoP checks and blocking jobs.

• Regular destruction runs.

• Legal hold propagation.

• Audit reporting for compliance evidence.

  
  

A structured runbook ensures repeatable and auditable processes.

10. GDPR vs. CCPA in ILM

Understanding the differences between GDPR and CCPA is crucial for effective compliance:

• GDPR “Right to be Forgotten” → Implemented via residence → block → destroy cycle.

• GDPR “Restriction of Processing” → Fulfilled through blocking with restricted access.

• CCPA “Right to Delete” → Similar to GDPR deletion flow.

• CCPA “Do Not Sell” → Managed outside ILM (purpose/consent management), but ILM ensures data is blocked/destroyed appropriately.

  
  

11. Future-Proofing Your Compliance Strategy

As regulations evolve, so must your compliance strategies. Staying informed about changes in data privacy laws is essential. Regularly review and update your ILM configurations to align with new requirements. This proactive approach will help mitigate risks and ensure ongoing compliance.

Conclusion

Configuring SAP ILM for GDPR and CCPA is not just a technical task—it’s a compliance strategy. By activating the right functions, defining audit areas, setting retention rules, and implementing blocking, destruction, and legal holds, you create a future-proof compliance framework.

With these steps, your SAP systems can meet global data privacy requirements while keeping business operations compliant, auditable, and efficient. For more information on SAP Archiving On Demand Services, visit SAP Archiving Services.