Any retention period should run from either the cessation of the processing to which the PIA relates, or it being superseded by a later PIA e.g. where there is a triggering material change in the processing requiring a fresh / review of the PIA.
The period is really for you to assess having regard to the factors you have described and the nature of your business and risk. I doubt whether you would ever need 12 years. Six is certainly safe. I could probably justify three in some scenarios.
On the other hand for the specific scenario you mention, assuming an end point of "review" as opposed to "auto dispose" I can see a strong argument for transfer to permanent archive.
In practice I have already seen several database implementations linked to an Information Asset Register where there is in fact no disposal mechanism or procedure. An asset may be decommissioned along with associated objects such as PIAs but the records are simply retained.
I see no problem with that.
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