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How the schedule works. Section 8(7) of the DPDP Act 2023 requires personal data to be erased, and Data Processors to be made to erase it, once the purpose is no longer served, unless retention is necessary to comply with a law; from 13.05.2027 Rule 8(3) also requires the personal data, traffic data and logs of any processing to be kept for at least one year from the processing, for the State purposes in the Seventh Schedule, and then erased unless a law requires otherwise. Each row below states the longer of the statutory period and the period the Company needs for its purpose and for claims, with the claims period in mind (generally three years under the Limitation Act 1963, and three years for claims under s.45 of the Code on Wages 2019). Rule 8(1) and (2), with the forty-eight hour notice before erasure, apply only to the classes in the Third Schedule (large e-commerce, online gaming and social media intermediaries) and not to an employer's records. Periods in square brackets are policy periods for the Company to confirm; a period stated without brackets is the statutory minimum as verified when this format was stated on 30.10.2026.

[Name of the Company] · Employee personal data retention and erasure schedule · Version [Version number of the schedule] · Approved by [Approving authority for the schedule] on [Date of approval of the schedule]

Applies to: all personal data of candidates, employees, former employees, trainees, interns and apprentices, and of the family members, nominees and emergency contacts whose details they give, held by the Company or by its Data Processors in any form.

Legal hold. No record is erased while it is subject to a legal hold. HR, Finance and IT suspend erasure of the records concerned on receipt of notice of a claim, a complaint to any authority, an inspection, a summons, an investigation or a proceeding, or where [Designation who may issue a legal hold] issues a hold, and resume only when the hold is released in writing.

A. Recruitment

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