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First documentHandling Legacy Data Collected Before DPDP: A Board-Level PlanOpen original ↗
A-047
Second documentLog Retention, Deletion, and Audit Trails: Building anOpen original ↗
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First paragraph172 words
Executive checklist and common questions on DPDP legacy data
Current interpretations of the notified DPDP Rules indicate a general compliance window of around twelve months from notification for most obligations, with scope for phased commencement by sector, size, or risk profile. Within that window, Section 5(2) and the Rules expect Data Fiduciaries to provide DPDP-compliant notices to individuals whose data was collected earlier and whose consent is being carried forward. In practice, a medium to large enterprise will often need the full 12–18 months to inventory, classify, and remediate legacy datasets in a structured way. Missing the window does not mean that all your processing becomes automatically unlawful overnight, but it does increase your exposure: if you have not provided required notices, cannot demonstrate a lawful basis for ongoing use of legacy data, or are unable to respond to rights requests involving older datasets, you make it easier for the Data Protection Board to conclude that you have failed to meet your obligations, raising the likelihood of monetary penalties and binding directions to change or stop processing. [3]
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Second paragraph52 words
Designing a risk-based log retention model
Classify data sensitivity and regulatory applicability For each log source, flag whether it contains personal data, sensitive business data (e.g., financial transactions), or only technical metadata. Mark which systems fall under CERT-In Directions and other sectoral requirements so that the 180-day baseline for covered systems is clearly visible. [3]