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Data Lifecycle Management

Data Retention & Disposal Policy

Effective Date: 1 January 2025 • Last Updated: 30 October 2026

1. Policy Objective & Statutory Alignment

This policy defines the retention schedules and disposal procedures for data processed by Staff Mitr, reconciling Section 8(7) of the DPDP Act, 2023 (data erasure upon purpose fulfillment) with mandatory Indian record-keeping statutes, including the Income Tax Act, 1961, the Companies Act, 2013, and the Code on Wages, 2019.

2. Dual-Tier Retention Schedule

Data Category Active Retention Statutory Archive Period Disposal / Purge Method
Biometric Facial Embeddings & Landmark Vectors Duration of active employment None (Immediate Privacy Purge) Irreversible cryptographic wipe (purge_biometrics())
Attendance Ingress Timestamps Active subscription 3 Years (Code on Wages, 2019) Automated table partition drop after 3 years
Raw GPS Punch Coordinates 90 Days rolling window Aggregated status preserved; raw coordinates wiped Automated Celery task wipes coordinates older than 90 days
Salary Registers, Payslips & Bonus Batches Active employment 8 Financial Years (Income Tax Act Sec 44AA) Soft-deleted archive; purged after statutory period
Adolescent Compliance Records (Ages 14–17) Until worker turns 18 + 3 years 3 Years post-separation Permanent document deletion from secure vault
Security & Audit Logs 180 Days hot storage 1 Year cold archive (CERT-In 2022) Cryptographic archival shredding

3. Account Termination & Offboarding

  • 30-Day Export Window: When an organization terminates its subscription, it is granted a 30-day grace period to export employee profiles, attendance logs, and payslips (CSV/Excel/PDF).
  • Cryptographic Shredding: Following the 30-day export window, all tenant facial biometric vectors are permanently wiped, and active database records are sanitized in accordance with NIST SP 800-88 Revision 1 standards.

4. Legal Holds

Standard automated disposal schedules are suspended under a formal Legal Hold if an active regulatory notice, court order, or labour dispute is served on the Customer or Staff Mitr.