Deletion Workflow Audit
Liability Check
The DPDP Act mandates the right to erasure for all personal data. Fail to delete data across all systems—production, backups, SaaS processors—when requested, and you're inviting penalties up to ₹250 Crore.
Why Deletion Workflow Audit is at Risk
The **DPDP Act 2023** grants Data Principals the explicit **right to erasure** (Section 13), meaning they can demand their personal data be deleted. This isn't just about your production databases. Your liability extends to every copy of that data: **backup servers in Hyderabad's data centres, SaaS tools like Salesforce or HubSpot, even old customer support tickets in Zendesk.** A patchy deletion workflow leaves sensitive PII lingering, creating a massive compliance gap. The Data Protection Board expects demonstrable proof that data is purged completely, not just marked as inactive.
Common Violations
- 1.Deleting data only from primary production databases, leaving copies in backups or archives.
- 2.Failing to send deletion requests to all third-party SaaS processors (e.g., CRM, marketing automation) handling the data.
- 3.Not having a verifiable audit trail for deletion requests, showing when and how data was purged across systems.
The Immediate Fix
Start by creating a comprehensive data inventory to identify every location where personal data resides—from your Chennai development servers to your cloud storage and every SaaS vendor. Then, draft a formal deletion workflow that mandates purging data from ALL these identified systems within the DPDP-stipulated timeframe. This needs to be auditable.
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Need help checking your business?
- Start with the free self-check to find questions for your team.
- Our paid gap assessment takes four weeks. We check your apps, documents and records, then list what needs fixing.
- Fixing the agreed gaps takes two to three months. A final assessment checks the completed work.
Save your results and discuss the questions with your team.
Next step after the audit
The audit shows the gaps. Sanctum closes them. One programme covers legal position, data map, gap analysis, implementation, tooling, training, a written readiness opinion, and breach cover, under one accountable owner. See the all-in-one programme
What Should You Do Next?