Data Retention Schedule Audit
Liability Check
Holding onto customer KYC documents or employee payroll data longer than legally required is a ticking time bomb under DPDP, inviting heavy fines for unlawful data processing.
Why Data Retention Schedule Audit is at Risk
The DPDP Act demands **purpose limitation** (Section 6). This means personal data like **Aadhaar numbers** or **financial transaction logs** can only be retained as long as necessary for the purpose for which it was collected or as legally mandated. Retaining data beyond this period is a direct violation, turning old data into fresh liability. Imagine a data breach at a Bangalore tech park exposing customer data from 2010 that should have been purged years ago. Conversely, deleting data too soon could violate other sectoral regulations (e.g., SEBI, RBI KYC norms), creating a compliance paradox. Your retention schedule must navigate this tightrope.
Common Violations
- 1.No documented data retention policy or schedule across the organisation.
- 2.Retaining old customer support chat logs, inactive user profiles, or dormant applicant resumes indefinitely in systems like Zoho CRM or Workday.
- 3.Inconsistent retention periods applied across different data processing systems (e.g., Salesforce, SAP, HRMS) for the same data type.
The Immediate Fix
Map out all personal data processed across your systems (e.g., Salesforce, SAP, internally built HR portals). For each data type, determine its purpose, the legal basis for processing, and the maximum retention period required by law or business necessity. Create a draft retention schedule document and assign ownership.
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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?