Data Retention Policy
Operated By: Sachin Rathod, operating as OuterCircle Labs
Effective Date: August 11, 2026
Version: v1.0.0
Summary
Data lifecycle policy defining retention periods, deletion triggers, and cryptographic erasure procedures across profile data, consent logs, and operational telemetry.
Key Highlights
- Retention only for required business and legal purposes.
- Automatic purging on account deletion, direct record deletion, inactivity, or retention expiry.
- Cryptographic erasure and rolling backup overwrite.
- Auditability for consent and compliance records.
Retention Schedule Matrix
| Category | Examples | Retention Period | Basis | Deletion Trigger |
|---|---|---|---|---|
| Account Master Data | User ID, full name, email, phone, authentication metadata | Active account lifetime plus 2 years post-dormancy | Service provision, identity management, dispute defense | Account deletion or 24 months inactivity |
| Address Data | Saved home, office, delivery addresses | Active account lifetime plus 2 years post-last usage | Consent autofill and user convenience | Direct address deletion or account deletion |
| Consent Records and Ledger | App ID, scopes, timestamps, revoke status | Minimum 3 years from grant or revocation event | DPDP accountability and audit proof | Expiry of 3-year audit window unless legal hold applies |
| Authentication and Security Logs | Login timestamps, IP, user-agent, MFA telemetry | 1 to 2 years rolling | Fraud prevention and forensics | Automated rotation after 730 days |
| API Usage and Developer Logs | Request metadata, endpoint telemetry, latency | 1 to 3 years | Billing and rate-limit auditing | Automated purge at retention boundary |
| Support Tickets and Correspondence | Grievance emails, support tickets, chat logs | 2 to 3 years from resolution | Support continuity and legal defense | Purge 3 years after resolution |
| Encrypted Disaster Recovery Backups | Production datastore snapshots | 30-day rolling cycle | Disaster recovery and continuity | Automatic cryptographic overwrite on cycle expiry |
| Anonymized Aggregate Telemetry | Aggregate usage trends and MAU metrics | Indefinite after irreversible anonymization | Product analytics and benchmarking | Not applicable |
1. Purpose and Scope
This policy standardizes retention, archival, and secure disposal across production databases, telemetry pipelines, cloud infrastructure, and backups in line with DPDP Act Section 8(6).
2. Core Retention Principles
- Purpose limitation: data kept only as long as required for its original purpose.
- Storage minimization: avoid indefinite retention and use shortest practical compliant duration.
- Proactive disposal: erase or irreversibly anonymize after purpose completion or legal retention expiry.
3. Deletion and Cryptographic Erasure Procedures
- Logical invalidation from active APIs and auth gates.
- Primary physical purge from operational databases.
- Backup expungement through rolling encrypted backup cycles.
- Irreversible anonymization for long-term aggregate telemetry.
4. Legal Holds and Regulatory Exceptions
Records may be temporarily retained beyond baseline schedules for legal obligations, court orders, investigations, or imminent legal claims. Standard schedules resume once the hold is lifted.
5. Policy Governance and Periodic Review
This policy is reviewed annually by the Data Protection Officer and Legal Counsel. Updates are published with incremented versioning when legal or regulatory requirements evolve.