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The Act
The DPDP Act, explainedThe DPDP Rules 2025

Ch IPreliminary

S.1 Short title and commencementS.2 DefinitionsS.3 Application and scope

Ch IIObligations of Data Fiduciary

S.4 Grounds for processingS.5 NoticeS.6 ConsentS.7 Certain legitimate usesS.8 Data Fiduciary obligationsS.9 Children’s dataS.10 Significant Data Fiduciary

Ch IIIRights and duties of Data Principal

S.11 Right to accessS.12 Correction and erasureS.13 Grievance redressalS.14 Right to nominateS.15 Duties of the Data Principal

Ch IVSpecial provisions

S.16 Transfer outside IndiaS.17 Exemptions

Ch VData Protection Board of India

S.18 Establishment of the BoardS.19 Composition of the BoardS.20 Salary and term of officeS.21 DisqualificationsS.22 Resignation and vacanciesS.23 Proceedings of the BoardS.24 Officers and employeesS.25 Members as public servantsS.26 Powers of the Chairperson

Ch VIBoard powers and procedure

S.27 Powers and functions of the BoardS.28 Procedure followed by the Board

Ch VIIAppeal and dispute resolution

S.29 Appeal to the Appellate TribunalS.30 Tribunal orders as a decreeS.31 Alternate dispute resolutionS.32 Voluntary undertaking

Ch VIIIPenalties

S.33 Penalties and the ScheduleS.34 Penalties to Consolidated Fund

Ch IXMiscellaneous

S.35 Good-faith protectionS.36 Power to call for informationS.37 Blocking of accessS.38 Consistency with other lawsS.39 Bar of jurisdictionS.40 Power to make rulesS.41 Laying of rules before ParliamentS.42 Power to amend the ScheduleS.43 Power to remove difficultiesS.44 Amendments to other Acts
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Data mapping collection · Keep it, then remove it

Data Retention and Erasure Mapping Under the DPDP Act

The DPDP Act does not give one deletion period for all personal data. It asks you to erase data when its purpose is served or consent is withdrawn, unless a law requires you to keep it. This guide shows how to map that for your own business: what starts the clock, how long you keep each kind of data, where the copies sit, who deletes them and what proof you keep. It includes a worked example and a free Excel register, sent after a short form.

By the DPDPActIndia editorial team · Last updated 4 October 2026 · About 44 minute read · Checked against the Act text and the DPDP Rules, 2025 · Editorial policy

In short

Retention and erasure mapping links every kind of personal data to a reason for keeping it, a trigger that starts the clock, a period, the places where copies sit, the way they are deleted and the proof that it happened. Retention decides when data should go. Erasure is how it goes. You cannot design the second without the first, so map them together. The Act sets no single period for everything, so each rule in your register must come from your own purpose or from a named law.

  • What the Act says: under Section 8(7) a Data Fiduciary must erase personal data when consent is withdrawn or when it is reasonable to assume the specified purpose is no longer served, whichever is earlier, unless retention is necessary for compliance with law. It must also cause its Data Processors to erase.
  • What it does not say: we found no provision that sets a universal retention period, a rule for backups, or a duty to keep a retention register. Named exceptions exist: one year for certain logs and, for named classes of Data Fiduciary, a three-year inactivity rule.
  • The method: a seven-link chain from purpose to proof, one register row per rule, one location row per copy.
Phase 1
Decide
Set the trigger, the driver and the period for each kind of data.
Phase 3
Prove
Run the deletion, confirm it, keep the record and review it.
In this article
  1. The basics
  2. What are data retention and erasure?
  3. The 7-link chain
  4. Why map retention and erasure?
  5. What the DPDP Act says
  6. Decide the rules
  7. How to identify retention triggers
  8. How to decide what should be retained
  9. Mapping periods to data categories and purposes
  10. Map the deletion
  11. Mapping erasure and deletion workflows
  12. Production systems, backups, spreadsheets and email
  13. Mapping processor and vendor deletion
  14. Consent withdrawal vs erasure
  15. Build and use it
  16. Building a retention and erasure register
  17. 10 common mistakes
  18. Step-by-step implementation
  19. Worked example: a customer account
  20. FAQ
  21. Related resources
  22. Primary sources

The basics

What are data retention and erasure? Plain definitions for a DPDP Act programme

Retention is the decision to keep personal data for a stated reason and for a stated time. Erasure is the act of removing it, including from every copy and from every Data Processor that holds it. Mapping means writing both decisions down for each kind of data, so that deletion happens on purpose and not by accident.

These terms are not defined separately in the Act, so this guide uses them in their everyday sense. Section 2 of the Act does list “erasure” among the operations that count as processing, and it defines a “specified purpose” as the purpose mentioned in the notice given to the Data Principal. That second definition matters most, because the erasure duty in Section 8(7) is tied to it.

Terms used in this guide
TermMeaning hereExample
Retention ruleA written decision on how long one kind of data is kept, why, and what starts the clock.Keep support tickets until 12 months after the ticket is closed (illustrative).
Retention triggerThe event or date that starts the clock.Account closure, invoice date, ticket closed.
Retention driverThe reason the data is still kept: purpose still served, law requires it, dispute or hold, or security log.Law requires retention of invoices.
Deletion triggerThe event that starts the erasure workflow.Retention period ended, consent withdrawn, erasure request.
ErasureRemoving the personal data from every place it sits, or making it impossible to link to a person.Database row deleted, backup expired, vendor copy deleted.
Erasure evidenceA record showing what was erased, when, by whom, and how you know.Job report, vendor confirmation, ticket.
Where this fits

Retention and erasure are the last two stages of the data flow in the data flow and processor mapping guide. The activity, purpose and applicable basis come from your personal data inventory. This page turns those two stages into rules you can run. For the whole collection, start at the complete data mapping guide.

The basics

The 7-link chain: from purpose to deletion proof

Every retention rule should follow one chain: purpose or requirement, retention trigger, retention period, system or location, deletion trigger, deletion mechanism, evidence. If a link is empty, the rule cannot be run. The most common empty links are the trigger and the evidence.

1Purpose or requirementWhy you hold it.Notice purpose or named law
2Retention triggerWhat starts the clock.Closure, invoice, last contact
3Retention periodHow long, and on what rule.Applicable requirement
4System or locationEvery place a copy rests.Including backups and vendors
5Deletion triggerWhat starts erasure.Period ended, consent withdrawn
6Deletion mechanismHow each copy goes.Job, vendor request, shred
7EvidenceProof it happened.Report, ticket, confirmation
↻ReviewRe-check when law, systems or vendors change.At least yearly
The chain applied to three kinds of data (periods are placeholders, not recommendations)
LinkCustomer accountInvoice recordServer log
1 Purpose or requirementRun the account, show past ordersKeep accounts, as a law requires (law to be named)Detect unauthorised access (Rule 6(1)(e))
2 Retention triggerAccount closureInvoice dateDate of the log entry
3 Retention periodA set time after closure, plus any holdThe period the named law setsAt least one year
4 System or locationOrder database, search index, analytics, backup, helpdesk, email exportsOrder database, finance spreadsheetLog archive, cloud host
5 Deletion triggerRetention period endedRetention period endedRetention period ended
6 Deletion mechanismScheduled job, vendor deletion, manual clean-upAnnual purge, manual deletionRotation job
7 EvidenceJob report, vendor email, ticketPurge report, finance sign-offRotation report

The basics

Why map retention and erasure? Five problems it prevents

Mapping turns “we delete when we can” into rules that people can run, check and explain. It is not an express requirement of the Act. It is practical compliance infrastructure that helps you meet the erasure duties the Act does contain.

What goes wrong without a map, and what the map gives you
Problem without a mapWhat it looks likeWhat the map gives you
Data kept with no reasonOld customer and applicant data sits in systems nobody reviews.A stated driver for every rule, so keeping has a reason.
Data deleted too soonA team deletes records that a law requires you to keep.A named legal source for any rule that says “law requires retention”.
Partial erasureThe main database is cleared, but the search index, spreadsheets, email and vendors still hold copies.A location list, so every copy has an owner and a method.
Vendor copies forgottenA Data Processor still holds data after you have deleted yours.Processor IDs on each rule and a confirmation column.
No proofSomeone asks what was deleted and when, and nobody can say.An erasure log with dates and evidence references.

There is also a plain security benefit. Data you no longer hold cannot be leaked. The Act itself does not make this argument, but it is the reason many security teams push for tidy retention.

The basics

What the DPDP Act says about retention and erasure: provisions, and what is missing

The Act ties erasure to the purpose and to consent, not to a calendar. Section 8(7) tells you to erase when consent is withdrawn or the specified purpose is no longer served, unless law requires retention. Rules 6 and 8 add a one-year log rule and a three-year inactivity rule for named classes. Nothing we found sets one period for all data.

Legal position

The table below is a short paraphrase. It is not a quotation, and it is not legal advice. Read the exact words in the Act and the Rules before relying on any row, and check the current Third and Seventh Schedules for Rule 8.

Provisions that bear on retention and erasure
ProvisionWhat it says, in shortWhat it means for the register
Section 2Defines “Data Processor”, “processing” (which includes erasure) and “specified purpose” (the purpose in the notice).The purpose column must match the notice.
Section 6(4) and 6(6)Withdrawing consent must be as easy as giving it. After withdrawal, the Data Fiduciary must cease, and cause its Data Processors to cease, processing within a reasonable time, unless the Act, the Rules or another law requires or authorises it.Withdrawal starts a stop-processing step and an erasure check.
Section 8(1) and 8(2)The Data Fiduciary stays responsible for processing done on its behalf. A Data Processor engaged for activities related to offering goods or services needs a valid contract.Vendor deletion is your responsibility, so it needs a contract term and a confirmation.
Section 8(7)(a)Erase personal data when the Data Principal withdraws consent, or as soon as it is reasonable to assume the specified purpose is no longer served, whichever is earlier, unless retention is necessary for compliance with law.The core duty. The trigger, driver and legal source columns come from it.
Section 8(7)(b)Cause the Data Processor to erase personal data that was made available to it.The processor IDs and confirmation columns.
Section 8(8) and Rule 8(1) and 8(2)The purpose is deemed no longer served if the Data Principal neither approaches the Data Fiduciary for it nor exercises rights for a prescribed period. The Rules prescribe three years from the last approach or exercise of rights, for the classes in the Third Schedule (e-commerce, online gaming and social media entities, within the stated thresholds), unless a law requires retention. The Data Fiduciary must give notice at least 48 hours before erasing.Applies only to those named classes. Do not copy it into rules for other businesses.
Rule 6(1)(e)Reasonable security safeguards include keeping logs and personal data for one year for the purposes the clause lists, unless a law requires otherwise.A security-log rule with a one-year minimum.
Rule 6(1)(f)Appropriate security provisions in the contract with a Data Processor.Where deletion terms can sit in the vendor contract.
Rule 8(3)A minimum of one year for personal data, traffic data and logs, for the purposes in the Seventh Schedule, after which the data is erased unless a law requires longer.A second route to a one-year minimum for logs.
Section 12(3)A Data Principal who has asked for erasure can have it erased, unless retention is necessary for the specified purpose or for compliance with law. Section 12 rights are framed around processing based on consent, including consent under Section 7(a).An erasure-request trigger with a hold check.
Section 17(4)Exempts certain State processing from the Section 8(7) erasure duty and from Section 12(3).Check only if you are a State instrumentality.
Rule 15A Data Fiduciary must meet requirements the Government specifies by order about making personal data available to a foreign State or its agencies.Relevant if any retained copy is held abroad.

What we found no provision on

  • A single retention period, such as “delete after 90 days”, for all personal data.
  • How to treat backups. The Act is silent, so your own written approach has to fill the gap.
  • A duty to keep a retention schedule, a retention register or an erasure log.
  • A fixed number of days for finishing erasure after a trigger under Section 8(7).
  • Any wording like a “right to be forgotten”. Section 12 uses “erasure” and ties it to the conditions above. The Act has no GDPR-style “legitimate interest” ground either, so, in our reading, a business wish to keep data is not by itself a reason to retain it.
Do not write “DPDP says delete after X”

The only fixed periods we found are narrow: one year for the log rules, and three years of inactivity for the named classes in Rule 8. Everything else is your own rule, justified by your own purpose or by a named law. The periods in this guide's examples are placeholders.

Decide the rules

How to identify retention triggers: the event that starts the clock

A retention trigger is a dated event that already exists in a system, such as an account closure date, an invoice date or a ticket close date. A period such as “one year” means nothing until you say one year from what. If the date is not stored anywhere, a deletion job cannot find it.

Common retention triggers and where to find the date
Trigger typeExamplesWhere the date usually sitsWatch for
End of a relationshipAccount closed, contract ended, employee exit, subscription cancelled.CRM, billing system, HR system.Accounts that are never formally closed. Add an inactivity rule.
Completion of a taskOrder delivered, ticket closed, claim settled, hiring decision made.Order system, helpdesk, applicant tracker.Records left open for years. Add a stale-record rule.
A record dateInvoice date, date of a log entry, date of a form.The record itself.Dates held only in free text or PDF files.
Consent withdrawnUnsubscribe, withdrawal through a preference centre or by email.Consent records, email platform.Withdrawals made by phone or chat that never reach the record.
An erasure requestA Data Principal asks you to erase their data.Request log, grievance system.Requests sent to the wrong inbox.
InactivityNo login, no purchase, no contact for a set period.Last-activity fields.Rule 8 sets a three-year inactivity period only for the named classes. For others, the period is yours to justify.
A holdDispute, investigation, audit, legal claim, or a regulator’s direction.Legal or compliance team.A hold must pause the clock. Record who placed it and when it ends.

A quick test for a good trigger

  1. Is it an event or a date? “When we no longer need it” is not a trigger.
  2. Is it stored in a system? If not, add a field before you write the rule.
  3. Does one person own it? Someone must keep the date accurate.
  4. Can a job read it? A trigger only a human can see makes deletion manual and slow.
Tip

If you cannot find a trigger, that is a finding. Write “No retention trigger” in the gap column of the register and ask the system owner to add the field.

Decide the rules

How to decide what should be retained: a six-question test

Keep personal data only while one of three reasons applies: the specified purpose is still being served, a named law requires you to keep it, or a dispute or hold needs it. If none applies, the data is a candidate for deletion. Ask the questions below in order and write the answer in the register.

  1. Is the specified purpose still being served? Use the purpose in the notice. A new or vague reason, such as “it may be useful later”, is not the specified purpose.
  2. Has the Data Principal withdrawn consent for this purpose? If yes, stop processing and move to the erasure check in the next step. Section 8(7)(a) points to erasure on withdrawal.
  3. Does a law require you to keep it? Name the law and the section. “Compliance needs it” without a source is not enough to write “law requires retention” in the register.
  4. Is there a dispute, claim, investigation or audit? If yes, a hold applies. Record who placed it and when you will review it.
  5. Is it a security log under Rule 6(1)(e) or Rule 8(3)? If yes, the one-year minimum applies, unless another law requires longer.
  6. Does a class-specific rule apply to you? Read Rule 8 and the Third Schedule to see whether the three-year inactivity rule covers your business and your purpose.
Keep, restrict, anonymise or delete: what each outcome means
OutcomeWhen it fitsCare needed
Keep in useThe specified purpose is still being served.Re-check at each review. Purposes end.
Keep, with restricted accessA law requires you to keep it, or a hold applies, but the data is no longer needed for day-to-day work.Move it out of everyday systems. Limit who can open it. Use it only for the retention reason.
AnonymiseYou want to keep statistics but not the person.If the data can still be linked to a person, it is still personal data. Test whether re-identification is possible before you rely on this.
DeleteNo purpose, law or hold remains.Delete from every location in the register, including vendors.

Where to look for legal retention requirements

The Act does not list the other laws that may require you to keep records. Their periods differ by law and sector, and they change, so this guide does not list periods. Ask your finance, legal and HR advisers to confirm the law and the section for each category. Areas that usually need a check:

  • Tax and GST laws, for invoices, ledgers and payment records.
  • Company law, for statutory registers and accounting records.
  • Labour and employment laws, for payroll, attendance and employee files.
  • Sector regulators, for example in banking, insurance, securities, telecom or health.
  • Cyber security directions, for logs.
Name the source

In the register, a rule marked “Law requires retention” with no named law is flagged as “Legal source missing”. This stops “the law says so” from becoming a reason to keep everything.

Decide the rules

Mapping retention periods to data categories and purposes: how to write a rule you can run

Write each rule in one sentence: delete [data] [time] after [trigger], unless [hold]. Set one rule per category and purpose, not one rule per system. The period comes from the purpose or from a named law. The table shows how to reach a period for common categories, without suggesting one.

No recommended periods

This table shows how to decide, not what to decide. Any number you see in an example is a placeholder. Your period must come from your own purpose and the laws that apply to you.

How to set the period for common data categories
CategoryTypical purposeTypical triggerHow to reach the period
Customer account dataRun the account, show past ordersAccount closure or an inactivity pointAsk how long the purpose really lasts after closure. Add a hold for disputes. Check Rule 8 if you are in a named class.
Order and invoice recordsDeliver the order, keep accountsInvoice dateAsk Finance which tax and accounting laws apply. Use the longest requirement that applies. Name the law.
Marketing subscribersSend the newsletter or offersConsent withdrawn, or an inactivity pointKeep until withdrawal. Set a stale-subscriber rule you can justify under the notice.
Support ticketsAnswer the queryTicket closedAsk how long a ticket stays useful for follow-up or disputes. Do not keep ticket text for longer than that.
Job applicantsAssess candidates for a roleHiring decisionKeep for the hiring purpose. Keep for future roles only if the candidate has agreed.
Employee recordsEmployment, payroll, statutory returnsEmployee exitAsk HR which labour and tax laws apply. Name each law.
Security logsDetect and investigate unauthorised accessDate of the log entryApply the one-year minimum in Rule 6(1)(e) and Rule 8(3), and any longer period another law sets.
Children’s dataAs stated in the noticePurpose servedRead Section 9 first. Verifiable parental consent and limits on tracking affect what you may keep and why.

A rule template

Delete the customer account data 30 days after account closure, unless a dispute or a legal hold is open. If a hold is open, delete 30 days after it ends. Source: purpose in the notice. Placeholder period.

The same rule in register terms has a trigger (account closure), a driver (purpose still served), a period (30 days after trigger, paused by hold), a method (delete) and evidence (job report). Notice that the sentence names its own exception. Every rule needs one.

Longest-period traps

When two reasons apply to the same data, the longer one usually wins, but only for the data the law covers. For example, if a tax law requires the invoice and not the customer’s phone number, you can delete the phone number on the account rule and keep the invoice on the legal rule. Split the categories so each rule keeps only what its reason covers.

Map the deletion

Mapping erasure and deletion workflows: six steps from trigger to record

An erasure workflow has six steps: detect the trigger, check for a hold, list every copy, delete or anonymise each one, get confirmation from vendors, and record the result. Write one workflow per trigger type, not one per system. The Act sets no fixed number of days for finishing erasure under Section 8(7), so set your own internal target and write it down.

1Detect the triggerPeriod ended, consent withdrawn, request received.Output: erasure ticket
2Check for a holdLaw, dispute, investigation.Output: go or hold
3List every copyUse the locations sheet.Output: locations to clear
4Delete or anonymiseRun each method.Output: cleared copies
5Confirm with vendorsTell each Data Processor.Output: confirmations
6Record the resultDates, people, evidence.Output: erasure log row
One workflow per trigger type
Deletion triggerWhat starts itHold checkMain ownerEvidence
Retention period endedA scheduled job finds records past their date.Automatic hold flag, plus a monthly legal check.System ownerJob report.
Account closedThe customer closes the account, or you close it.Check open orders, disputes and legal requirements.OperationsClosure ticket and job report.
Consent withdrawnA withdrawal arrives through any channel.Check whether another purpose or law still needs the data.Privacy leadWithdrawal record and deletion record.
Erasure requestA Data Principal asks you to erase their data.Check Section 12(3) conditions: purpose and law.Privacy leadRequest log and reply.
Purpose servedThe activity ends, for example a campaign closes or a hiring round ends.Check disputes and legal needs.Business ownerClosure note and job report.
Inactivity period endedNo contact or use for the set period. Rule 8 gives three years for named classes only.Check legal needs. Give the 48-hour notice if Rule 8 applies.Privacy leadNotice copy and job report.

Delete, anonymise or archive: record which one you do

Deleting removes the data. Anonymising keeps a version that cannot be linked to a person. Archiving with restricted access keeps the data for a reason such as a legal requirement, and should be used only for that reason. These are different outcomes, so the register has a method column and asks you to pick one. Do not describe archiving as deletion in a report.

Partial erasure

If a person asks you to erase their data and part of it must stay for a legal reason, delete the rest and tell them what stays and why. Record both in the log. A half-done erasure with no note looks the same as a failed one.

Map the deletion

Production systems, backups, spreadsheets and email: where copies hide and how to clear them

Personal data usually lives in more places than the system you think of as the source. A location sheet lists every place a copy rests, who can delete from it, how it goes and how long it takes. The longest time on the sheet is your real erasure time.

Where copies sit and a practical way to clear each
LocationWhy it gets missedPractical approach
Production databaseIt is the obvious one, so it is done first and the rest are forgotten.Scheduled delete or anonymise by trigger date. Keep the job report.
Replicas, caches and search indexesThey are rebuilt from production, so people assume they follow.Confirm the index drops the record. Record the rebuild time.
Analytics and data warehouseCopies are loaded in bulk and live for years.Remove identifiers before loading, or delete by key on a schedule.
Test and development copiesTeams copy production data for testing.Mask data in test, or add the copies to the location sheet.
BackupsThey are designed to keep data. Deleting one record from a backup is often not possible.See the backup note below.
Logs and monitoring toolsThey hold IP addresses and user IDs, and are kept for security.Apply the one-year minimum where it applies, then rotate out.
Spreadsheets and exportsFinance, sales and HR keep their own files.Name an owner for each file. Ask for a regular clean-up.
Email, chat and attachmentsReports, forms and CVs travel by email and sit in inboxes.Set a mailbox clean-up step. Store the original in the system, not in email.
Laptops, phones and removable mediaDownloads and local copies are not tracked.Ask staff to delete downloads. Use managed storage where possible.
PaperForms and files sit in cabinets.Set a shredding date and a witness or record.
Processor systemsYou cannot see inside them.See the vendor section below.

Backups: the Act is silent, so write down what you do

We found no provision in the Act or the Rules that says how backups should be treated when erasure is due. That gap is real, and a clear written approach is the sensible way to cover it. This is good practice, not a legal requirement:

  • Keep backup cycles short and documented. Record how long each backup is kept and when the oldest copy expires.
  • Limit access. Backups should be used only to restore service, not to look up customers.
  • Keep a deletion log. After any restore, run the log again so erased data does not return to production.
  • Ask your host. Check how your cloud host or backup vendor ages out copies, and keep their written answer.
  • Do not claim more than you do. If a backup holds a copy for 35 days (a placeholder), say so in the register.
Take advice

How far a backup must be cleared after erasure is a legal question without a clear answer in the text we reviewed. Get advice from a lawyer, and review it if the Board or a court gives guidance.

Map the deletion

Mapping processor and vendor deletion: how to make sure their copies go too

Section 8(7)(b) requires you to cause your Data Processor to erase personal data you made available to it, so vendor deletion is part of your own erasure workflow. Add every processor that holds a copy to the rule, record how erasure is requested, and file the vendor’s confirmation.

Seven questions to ask each Data Processor about deletion
QuestionWhy ask itWhere to record the answer
1. Which of our data do you hold?You cannot request deletion of what you have not listed.Processor ID on the register row.
2. How do we ask you to erase it?Some vendors offer an interface, others need a ticket or an email.Deletion method on the location row.
3. How long until it is gone?This sets the lag you report.Time to disappear.
4. What about your backups?Backups are the usual gap.Backup handling on the register row.
5. Who do you pass it to?Sub-contractors may hold copies. We found no provision in the Act that names sub-processors, but Section 8(1) keeps you responsible.Sub-processors known, in the processor register.
6. How do you confirm?You need proof, not an assumption.How you confirm, and the confirmation date in the log.
7. What happens when the contract ends?Data must not stay behind after you leave.Processor contract terms.

What the Act and Rules say

  • A valid contract with the Data Processor (Section 8(2)).
  • You stay responsible for processing done on your behalf (Section 8(1)).
  • You must cause the processor to erase data made available to it, when erasure is due (Section 8(7)(b)).
  • You must cause the processor to cease processing after consent is withdrawn, unless the law requires or authorises it (Section 6(6)).
  • Appropriate security provisions in the processor contract (Rule 6(1)(f)).

Good practice to ask for

  • A contract clause on return or deletion at the end of the service.
  • A stated time for deletion after your instruction.
  • Written confirmation, with a date, for each deletion.
  • A list of sub-contractors and notice of changes.
  • A clear statement on how backups age out.
Processors and other recipients

Section 8(7)(b) speaks of a Data Processor. A recipient that decides its own purposes may be a Data Fiduciary in its own right, and your arrangement with it depends on the facts. Classify each recipient first using the five-question test in the data flow and processor mapping guide, and take legal advice if the role is unclear.

Map the deletion

Handling consent withdrawal vs erasure: five events that look alike and are not

Consent withdrawal, an erasure request, the end of a purpose, inactivity and the end of a retention period each have their own source and their own checks. Withdrawal and the end of a purpose are duties under Section 8(7)(a). An erasure request is a right under Section 12(3). Inactivity is a deemed end of purpose that the Rules define only for named classes.

Five deletion events compared (short paraphrase, not a quotation)
EventSourceWhat you must doWhen you may keep the data
Consent withdrawnSections 6(4), 6(6) and 8(7)(a)Make withdrawal as easy as giving consent. Cease processing, and cause processors to cease, within a reasonable time. Erase.Where law requires or authorises the processing, or retention is necessary for compliance with law.
Erasure requestSection 12(3)Erase the data when the Data Principal asks.Where retention is necessary for the specified purpose or for compliance with law.
Purpose no longer servedSection 8(7)(a)Erase as soon as it is reasonable to assume the purpose is no longer served.Where retention is necessary for compliance with law.
Inactivity period endedSection 8(8) and Rule 8(1), 8(2)For named classes only: treat the purpose as no longer served after the prescribed inactivity period, and give notice at least 48 hours before erasing.Where a law requires retention.
Retention period endedYour own registerRun the deletion job and record the result.Where a hold has been placed.

Withdrawal works at the level of the purpose, not the person

A customer who withdraws consent for marketing has not asked you to close their account. Stop the marketing, erase what only the marketing purpose needed, and keep what the account purpose still needs. If you have mapped each purpose in the inventory, you can see which rows each withdrawal touches. Section 6 also says that withdrawal does not make earlier lawful processing unlawful, so you need not undo what was done before.

Two clocks

On withdrawal, two things happen: processing stops, and erasure follows unless something requires retention. Record both in the log, with a date for each. Our consent withdrawal guide covers the design of the withdrawal channel.

Do not copy Rule 8 across

The three-year inactivity rule applies only to the classes named in the Third Schedule, with their own purposes and thresholds. It is not a general rule for all businesses. If you are outside those classes, you still need to decide when a purpose ends, and justify the choice under Section 8(7)(a).

Build and use it

Building a retention and erasure register: free Excel file, fields and example

The register is three linked sheets: a register of rules, a list of locations and a log of erasure events. The Excel file below contains all three, a filled example, gap flags and a summary. Enter your details on the download page to get the link.

DPDP Act Retention and Erasure Register 2026

Excel (.xlsx), about 30 KB. Sheets: Start here, Register (40 rows), Locations (60 rows), Erasure log (60 rows), Example, Summary, Lists. Gap flags are formulas. The example data and all periods in it are fictional placeholders.

The register uses the same activity IDs as the Data Inventory Workbook and the same processor IDs as the Data Flow and Processor Worksheet. You can also copy the columns below into any spreadsheet.

Register sheet: 18 fields and a gap flag

Register sheet: 18 fields
FieldWhat to enterWhy it matters
Register IDA unique ID such as R-001.Lets you point to one retention rule in a gap log or an erasure record.
Activity IDThe processing activity ID from your personal data inventory, such as PA-002.Joins the register to the inventory and the flow map.
Data categoryThe group of data this rule covers, for example account details or order records.Different categories often need different rules.
Specified purposeThe purpose in your notice, in the same words as the inventory.Section 8(7)(a) ties erasure to the specified purpose no longer being served.
Applicable basisConsent, a Section 7 legitimate use, or To confirm.Consent withdrawal is an erasure trigger under Section 8(7)(a). Other uses end with their own conditions.
Retention triggerThe event that starts the clock, for example account closure, invoice date, or last contact.A period without a trigger cannot be applied. Most failed schedules skip this.
Retention driverWhy the data is still kept: purpose still served, law requires retention, dispute or legal hold, security log, or To confirm.Section 8(7) allows retention only where the purpose is still served or retention is necessary for compliance with law.
Legal sourceIf a law requires retention, name the law and the section. Otherwise write None.A claim that "the law requires it" needs a named source. This column forces that.
Retention rule or periodThe rule in plain words, for example "30 days after account closure unless a hold applies".This is the rule your deletion job will run on.
Approved byThe person who approved the rule.Someone must own the decision to keep or delete.
Where copies restThe location IDs from the Locations sheet, or a short list.Production, backups, spreadsheets and email all hold copies.
Deletion triggerWhat starts erasure: account closed, consent withdrawn, purpose served, erasure request, inactivity period ended, or retention period ended.Connects the rule to the workflow that acts on it.
Deletion methodDelete, Anonymise, Archive with restricted access, or To decide.Anonymising and archiving are different outcomes. Record which one you use.
Processor IDsThe processor register IDs of vendors that hold this data.Section 8(7)(b) requires you to cause the Data Processor to erase data you made available to it.
Processors told and confirmedYes, No, Unknown, or Not applicable.Shows whether vendor deletion is proven or only assumed.
Backup handlingHow backups age out, and how you stop erased data returning after a restore.We found no provision that sets a backup rule. Write down what you do.
Deletion evidenceThe record that proves it: job report, ticket, vendor confirmation.Lets you show what was deleted, when, and by whom.
Last verifiedThe date someone last checked the rule against the real system.Shows how fresh the register is.

Locations sheet: 10 fields and a gap flag

Locations sheet: 10 fields
FieldWhat to enterWhy it matters
Location IDA unique ID such as L-001.Lets the register and the erasure log point to one place.
Register IDThe retention rule this copy follows.Joins the location to a rule.
LocationThe system, file, mailbox or place, for example order database or finance spreadsheet.One row per place a copy rests.
TypeProduction database, replica or search index, analytics store, backup, log, spreadsheet or export, email or chat, paper, laptop or phone, processor system, other.Backups and spreadsheets behave differently from production data.
OwnerThe person who can delete from this place.A copy with no owner is never deleted.
Processor IDThe processor register ID if a vendor runs this place.Joins the location to the vendor.
Deletion method hereHow the copy goes: delete, overwrite on cycle, vendor deletion, anonymise, shred.The method differs by location.
Time to disappearHow long after the trigger the copy is gone.The longest lag is your real erasure time.
How you confirmThe check that shows the copy is gone: job report, screenshot, vendor email.Evidence has to come from somewhere.
Last verifiedThe date this location was last checked.Shows how fresh the row is.

Erasure log sheet: 11 fields and a gap flag

Erasure log sheet: 11 fields
FieldWhat to enterWhy it matters
Log IDA unique ID such as E-001.One row per erasure event.
Register IDThe retention rule that applied.Joins the event to the rule.
TriggerAccount closed, consent withdrawn, purpose served, erasure request, inactivity period ended, retention period ended, or other.Shows why the erasure ran.
Trigger dateThe date the trigger happened.Starts your measure of how quickly you acted.
Hold checkedYes or No. Did someone check for a legal hold or required retention before deleting?Section 8(7) allows retention where necessary for compliance with law.
Systems clearedThe location IDs cleared.Shows which copies were handled.
Processors toldThe processor IDs that were told to erase.Section 8(7)(b).
Processor confirmation dateThe date the vendor confirmed.Shows vendor deletion is proven.
Completed dateThe date the last copy was cleared.Closes the event.
Done byThe person who completed it.Names who did the work.
Evidence referenceTicket number, report name or file location.Lets you find the proof later.

Example: three rules for the fictional store

Three retention rules for the fictional store (illustrative)
FieldR-001R-002R-006
Register IDR-001R-002R-006
Activity IDPA-002PA-001PA-006
Data categoryCustomer account: name, email, phone, addressOrder and invoice records: items, amount, billing addressServer access logs: IP address, user ID, time
Specified purposeRun the customer account and show past ordersDeliver the order and keep accountsDetect and investigate unauthorised access
Applicable basisConsentConsentTo confirm
Retention triggerAccount closure (customer closes it, or we close it after inactivity)Invoice dateDate of the log entry
Retention driverPurpose still servedLaw requires retentionSecurity log
Legal sourceNoneTax law, section to be confirmed by FinanceDPDP Rules, Rule 6(1)(e) and Rule 8(3): minimum one year
Retention rule or periodDelete 30 days after account closure unless a hold applies (illustrative)Period set by Finance after legal check (placeholder)At least one year from the log date, then delete unless another law requires longer
Approved byHead of Operations(blank)Head of IT
Where copies restL-001 to L-007L-001, L-006L-009
Deletion triggerAccount closedRetention period endedRetention period ended
Deletion methodDeleteDeleteDelete
Processor IDsP-001, P-003P-001P-001
Processors told and confirmedUnknownYesYes
Backup handlingBackups age out on a 35-day cycle (placeholder). Deletion log is re-applied after any restore.Backups age out on a 35-day cycle (placeholder).Log archive ages out with the same rule.
Deletion evidenceDeletion job report and ticketAnnual purge reportLog rotation report
Last verified2026-09-302026-09-302026-09-30
Gap flagProcessor erasure not confirmedNot approvedNone
How the gap flags work

A gap flag is a prompt to check, not a finding of non-compliance. A rule is flagged when it has no trigger, no period, an unconfirmed driver, a legal claim with no named source, no deletion method, vendor erasure that is not confirmed, no evidence, no approver or no verification date. A location is flagged when it has no owner, no method, no stated time, a missing processor ID or no verification. An erasure event is flagged when no hold check is recorded, it is not complete, a vendor confirmation is pending, or no evidence reference is given.

Build and use it

10 common retention and erasure mapping mistakes and how to fix them

Most failed retention programmes have no trigger, no source or no proof. These ten are the usual causes.

Common mistakes and fixes
MistakeWhy it hurtsFix
1. Writing “DPDP says delete after X”The Act gives no universal period, so the claim is wrong.Base each period on your purpose or a named law.
2. A period with no triggerNobody can tell when the clock starts.Name an event stored in a system.
3. “Law requires it” with no law namedIt becomes a reason to keep everything.Name the law and the section, or remove the claim.
4. One rule for the whole companyDifferent data has different reasons.One rule per category and purpose.
5. Clearing production onlySearch indexes, analytics, spreadsheets and email still hold copies.List every location and give each an owner.
6. Ignoring backupsErased data can return after a restore.Document the backup cycle and re-apply the deletion log.
7. Assuming vendors deleteTheir copies stay unless you ask.Tell each processor and file the confirmation.
8. Mixing up withdrawal and erasureYou erase too much or too little.Work at the level of the purpose and use the five-event table.
9. No hold checkYou delete data needed for a dispute or a legal requirement.Make the hold check a step in every workflow.
10. No evidenceYou cannot show what was deleted and when.Keep a log row with a date and a reference.

Build and use it

Step-by-step implementation: map retention and erasure in 7 steps

List the activities, set trigger, driver and period, name the legal source, record every location, map the workflow and processors, test with one real record, then approve and review. Each step names who is involved and what you should have at the end.

1List the activitiesFrom the inventory.Output: scope
2Trigger and driverWhy keep, and from when.Output: rule skeletons
3Legal sourceName each law.Output: sources
4Every locationSystems, files, vendors.Output: locations sheet
5Workflow and vendorsMethod, owner, confirmation.Output: workflows
6Test one recordDelete a test record end to end.Output: log row
7Approve and reviewSign off, then schedule reviews.Output: approved register

1List the activities and set the scope

What to do
Take the activities, purposes and applicable bases from your personal data inventory. Start with the ones that hold the most data or the most sensitive data, such as customer accounts, orders, support, marketing, hiring and logs. Give each one a register row.
Who to involve
The compliance lead and one business owner for each activity.
Watch for
Trying to cover every system at once. A short, finished register is worth more than a long, empty one.
Output
A list of activities with IDs and a register row for each.

2Set the trigger, the driver and the period

What to do
For each row, name the retention trigger and the driver (purpose still served, law requires retention, dispute or hold, security log). Draft the rule in one sentence, with its exception. Mark periods you cannot yet justify as “To confirm”.
Who to involve
The business owner, plus legal or compliance.
Watch for
Periods copied from another company. Yours must come from your own purpose or a named law.
Output
Draft rules with triggers and drivers.

3Name the legal source for every legal claim

What to do
For each rule that says “law requires retention”, write the law and the section in the legal source column. Ask Finance, HR and the sector lead to confirm. Remove the claim if no source is found.
Who to involve
Finance, HR, legal and any sector compliance owner.
Watch for
One long period applied to all data because one record needs it.
Output
A confirmed source, or a removed claim, for every legal rule.

4Record every location where copies rest

What to do
Use your data flow map to list every system, file, mailbox and vendor that holds the data. Add backups, logs, spreadsheets, email exports, laptops and paper. Give each location an owner, a deletion method and a time to disappear.
Who to involve
IT, the system owners and the team leads who keep their own files.
Watch for
Spreadsheets with no owner, and backups with no stated cycle.
Output
A locations sheet linked to each rule.

5Map the workflow and the vendors

What to do
Write one workflow for each deletion trigger: detect, check for a hold, list copies, delete, confirm with vendors, record. Add the processor IDs to each rule, ask each vendor the seven deletion questions, and record how the confirmation arrives.
Who to involve
The privacy lead, IT and the vendor owners.
Watch for
Vendors with no deletion clause in the contract. Note it and raise it at the next renewal.
Output
Workflows, processor IDs and a confirmation method for each rule.

6Test with one real record

What to do
Create a test customer, run the workflow from trigger to proof, and check each location and each vendor. Note how long each copy took to disappear. Record the run in the erasure log.
Who to involve
The privacy lead, IT and the vendor contacts.
Watch for
Copies you did not list. Add them, then run the test again.
Output
A completed log row and an updated locations sheet.

7Approve, then review on a schedule

What to do
Have each rule approved by its owner and fill in the verified date. Review the register at least once a year, and also when a law changes, a system is added, a vendor changes or a new purpose starts. Re-run the gap flags at each review.
Who to involve
Rule owners and the compliance lead.
Watch for
A register that is approved once and never opened again.
Output
An approved register with a review date.

Build and use it

Worked example: a customer account, from account closure to deletion record

Here is one chain, a customer account at a fictional online store, followed from purpose to proof. The store has seven places that hold the account data and two vendors. In the register, the rule is flagged because vendor erasure is not yet confirmed.

Illustrative only

The store, vendors and every period are fictional placeholders, not recommendations. Real periods depend on your own purpose and the laws that apply to you.

  1. 1 · Purpose or requirementRun the customer account and show past orders. The applicable basis is consent. The purpose matches the words in the notice and in the inventory (PA-002).
  2. 2 · Retention triggerAccount closure. The customer closes the account, or the store closes it after inactivity. The date is stored in the order database.
  3. 3 · Retention period30 days after account closure, unless a dispute or a hold is open (placeholder). The driver is “purpose still served”, which in this case covers a short window for reversing the closure and handling disputes. Invoices follow a separate rule (R-002) because a law the store has named requires them.
  4. 4 · System or locationSeven places. Order database, search index, analytics warehouse, nightly backup, helpdesk software, finance spreadsheet and email exports. Two are held by vendors: the cloud host (P-001) and the helpdesk (P-003).
  5. 5 · Deletion triggerThe retention period ends. A scheduled job reads the closure date and lists accounts past the 30 days with no hold.
  6. 6 · Deletion mechanismOne method per place. A scheduled job deletes from the database. The search index drops the record at the next re-index. The analytics store holds anonymised data. The backup expires on its 35-day cycle (placeholder). The helpdesk deletes on request. The spreadsheet and email exports are cleared by hand by named owners.
  7. 7 · EvidenceJob report, re-index log, vendor email, monthly checklist and a ticket. Each one is written to an erasure log row with a date.

Where the locations sheet shows gaps

Where copies rest: the locations sheet for the fictional store (illustrative)
IDLocationTypeOwnerDeletion method hereTime to disappearHow confirmedGap flag
L-001Order database (cloud host)Production databaseHead of ITDelete by scheduled jobNext nightly jobJob reportNone
L-002Site search indexReplica or search indexHead of ITRemoved at next re-indexWithin 1 dayRe-index logNone
L-003Analytics warehouseAnalytics storeData leadAnonymise before loadMonthlyPipeline run logNone
L-004Nightly backupBackupHead of ITExpires on its cycle35 days (placeholder)Host confirms the cycleNot verified
L-005Helpdesk softwareProcessor systemSupport leadVendor deletion on request(blank)Vendor emailTime not stated
L-006Finance spreadsheet of invoicesSpreadsheet or export(blank)Manual deletionYearlyFinance sign-offNo owner
L-007Email exports and attachmentsEmail or chatSupport leadManual deletionMonthlyMonthly checklistNone
L-008Email platform subscriber listProcessor systemMarketing leadVendor deletion on unsubscribeWithin 7 daysUnsubscribe recordNone
L-009Server log archiveLogHead of ITDelete on rotationAt the end of the periodRotation reportNone
What the sheet shows at a glance

Three locations are flagged: the backup has no verified date, the helpdesk software has no stated time to disappear, and the finance spreadsheet has no owner. The register row for the account rule is flagged too, because vendor erasure is not yet confirmed. The store fixes these before it relies on the rule.

The erasure log for three events

  1. E-001 · R-001Account closed. Trigger date: 2026-09-01. Hold checked: Yes. Cleared: L-001, L-002, L-003. Processors told: P-001. Vendor confirmation: 2026-09-03. Completed: 2026-09-03. Evidence: TKT-1042.
  2. E-002 · R-001Erasure request. Trigger date: 2026-09-10. Hold checked: Yes. Cleared: L-001, L-002. Processors told: P-003. Vendor confirmation: none yet. Completed: 2026-09-12. Evidence: TKT-1060. Gap flag: Processor confirmation pending.
  3. E-003 · R-003Consent withdrawn. Trigger date: 2026-09-15. Hold checked: not recorded. Cleared: L-008. Processors told: P-002. Vendor confirmation: none yet. Completed: not yet. Evidence: none. Gap flag: Hold not checked.
Reading the log

E-001 is complete. E-002 is an erasure request where the data is cleared but the helpdesk has not confirmed, so the event stays open. E-003 is a consent withdrawal with no hold check and no completion date, so it is still open. None of these flags is a finding of non-compliance. Each one is a prompt for the owner to close the gap.

FAQ

Frequently asked questions: data retention and erasure under the DPDP Act

Does the DPDP Act give a standard retention period for personal data?

We found no provision that sets one period for all personal data. Section 8(7) ties erasure to the specified purpose and to consent withdrawal, unless retention is necessary for compliance with law. Narrow fixed periods exist for security logs (one year) and for inactivity in named classes of Data Fiduciary (three years under Rule 8). Everything else is your own rule, justified by your purpose or a named law.

When must a Data Fiduciary erase personal data under the DPDP Act?

Under Section 8(7)(a), when the Data Principal withdraws consent or as soon as it is reasonable to assume the specified purpose is no longer served, whichever is earlier, unless retention is necessary for compliance with law. Section 12(3) adds erasure on a Data Principal’s request, subject to its own conditions. Read the exact words in the Act before you rely on this summary.

What is a retention trigger?

A retention trigger is the event or date that starts the retention clock, such as account closure, invoice date or the date a ticket is closed. A retention period only makes sense when it is measured from a trigger that is stored in a system.

Does the DPDP Act require a retention schedule or retention register?

We found no provision in the Act or the DPDP Rules, 2025 that requires one. A register is practical compliance infrastructure. It helps you meet the erasure duties the Act does contain, and it gives you a record of what you decided and why. See is data mapping mandatory under the DPDP Act.

How should we treat backups under the DPDP Act?

The Act and the Rules are silent on backups. A sensible written approach is to document each backup cycle, limit access, record deletions and re-apply them after any restore, and to get your host’s written answer on how copies age out. This is good practice, not a stated legal requirement, and it is worth legal advice for sensitive cases.

Do Data Processors have to delete data too?

Section 8(7)(b) requires the Data Fiduciary to cause its Data Processor to erase personal data that was made available to it. In practice, that means the contract should cover deletion, you should tell the vendor when erasure is due, and you should keep a confirmation. Section 8(1) keeps you responsible for processing done on your behalf.

What is the difference between consent withdrawal and an erasure request?

Withdrawal ends the consent for a purpose and starts a stop-processing and erasure duty under Sections 6 and 8(7)(a). An erasure request is a right under Section 12(3) that lets a Data Principal ask you to erase their data, subject to conditions. Both can lead to deletion, but they have different sources and checks, so log them as different triggers.

Can we keep personal data because a law requires it?

Section 8(7) allows retention where it is necessary for compliance with law, and Section 12(3) is similar. You should name the law and the section in your register. Keep only the data the law covers, and only for the period it requires, which differs by law. Ask your advisers to confirm each source.

Does the three-year inactivity rule apply to every business?

No. Rule 8(1) applies to the classes in the Third Schedule, which name e-commerce, online gaming and social media entities, with their own thresholds and purposes, and some purposes are excluded. It also requires notice at least 48 hours before erasure. Read the Schedule before assuming it applies to you.

How long must security logs be kept?

Rule 6(1)(e) lists keeping logs and personal data for one year among the security safeguards, and Rule 8(3) sets a minimum of one year for personal data, traffic data and logs for the Seventh Schedule purposes, after which they are erased unless a law requires longer. Check the exact clauses and any sector direction that sets a longer period.

What proof of erasure should we keep?

The Act does not set a format. A useful record shows the rule that applied, the trigger and its date, that a hold was checked, which locations and processors were cleared, the completion date, who did it, and a reference such as a job report, a ticket or a vendor email. The erasure log sheet in the free register has these fields.

Is anonymising personal data the same as deleting it?

No. Anonymised data can be kept only if it can no longer be linked to a person. If re-identification is still possible, it is still personal data. Record in the register whether you delete, anonymise or archive, and test for re-identification before you rely on anonymisation.

Related

Continue the data mapping collection

Go to the full method, the legal text and the practical tools. When you are ready to move from records to working controls, see the DPDP implementation framework.

Sources

Primary sources and regulatory references

  1. The Digital Personal Data Protection Act, 2023 (No. 22 of 2023), Gazette of India, 11 August 2023. Sections 2, 6, 8, 9, 12 and 17 are cited here.
  2. The Digital Personal Data Protection Rules, 2025, notified 13 November 2025 (G.S.R. 846(E)). Rules 6, 8 and 15, and the Third and Seventh Schedules, are cited here. See our DPDP Rules 2025 explainer.
  3. Our complete data mapping guide and section-by-section Act pages.
About this article. Prepared by the DPDPActIndia editorial team under our editorial policy. It explains the Act and Rules in general terms and is not legal advice (disclaimer). Provision summaries are paraphrases, not quotations. The seven-link chain, the six-question test, the register fields, the workflows and the backup approach are editorial guidance, not statutory requirements. All periods in examples are placeholders. We do not list retention periods under other laws, because they differ by law and change. Check the Schedules to the Rules and the laws that apply to you before relying on this page. Spotted an error? Tell us.