Data Retention Policy Under DPDP Act 2023
How long can you keep personal data under DPDP? Understanding data retention requirements, storage l. Get expert help today.
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DPDP Action Sheet
Use this before your next workflow goes live. It keeps the useful parts visible and turns DPDP into checks your team can actually answer.
For Data Retention Policy Under DPDP Act 2023, the DPDP question is how personal data enters the workflow, where it is stored, which tools touch it, what purpose was explained, and how deletion or withdrawal will work.
1. Lead Forms
Check:
- What data are you collecting?
- Is the purpose clear at the point of collection?
- Is marketing consent separate from service communication?
- Can the user withdraw consent later?
Common mistake: one checkbox that silently covers newsletters, sales calls, partner sharing and remarketing.
2. Email and WhatsApp
Check:
- Who is on the list?
- Where did consent come from?
- Is the list imported from a vendor, event, webinar, scrape or old CRM?
- Can you prove the source of consent?
Common mistake: treating every lead as permanently marketable.
3. Ads and Retargeting
Check:
- Are pixels or ad platforms receiving identifiable user behavior?
- Are audiences built from customer lists?
- Are lookalike or remarketing audiences using personal data?
Common mistake: assuming "the ad platform handles it" means your company has no DPDP responsibility.
4. Website Analytics
Check:
- Which tools run on the site?
- Are IP address, device identifiers, session IDs or form fields being captured?
- Is analytics used only for measurement, or also for profiling and targeting?
Common mistake: installing tools first and asking privacy questions later.
5. Vendor List
Make a quick list:
- CRM
- Email platform
- WhatsApp provider
- Analytics
- Ad pixels
- Form tool
- Landing page builder
- Webinar tool
For each vendor, answer: what data goes there, why, who can access it and how deletion works.
6. This Week's Action
Map one campaign from first click to final follow-up. Mark every place personal data is collected, enriched, shared, uploaded or used for targeting.
If your team cannot answer where the data came from and where it goes next, start with a data flow map before rewriting policy copy.
Book a DPDP clarity callNow think about your work. Where does personal data enter your workflows? Where does it sit? Who else touches it?
Frequently asked questions
Does the DPDP Act allow us to keep data for 10 years if our internal policy says so?
No, internal policies do not override the Act. You can only keep data if the original purpose still exists or if another Indian law specifically mandates a long-term retention period.
What happens to user data stored in our offline disaster recovery backups?
You must have a process to ensure that if a backup is restored, any data previously deleted under a "right to erase" request is not accidentally put back into your live systems.
Can we keep anonymized transaction data for business intelligence?
Yes, if the data is truly anonymized and cannot be linked back to an individual, it no longer qualifies as personal data under the DPDP Act and can be kept indefinitely.