Operations

How to Handle Deletion Requests

Audience: ops, support, product, founders · Last reviewed: March 2026

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Deletion rights become messy when teams do not know where data actually lives.

What the Act and Rules actually require

Erasure can come from two directions. Section 12(3) covers a direct request: the Data Principal asks, and you erase her data unless retention is still necessary for the specified purpose or required by another law. Section 8(7)–(8) covers the automatic trigger: once consent is withdrawn, or the specified purpose is no longer served (meaning the Principal has not approached you or exercised her rights for the prescribed period), you must erase — again unless law requires retention. Rule 8(2) requires giving the Principal 48 hours’ notice before that automatic erasure actually runs, so she can re-engage if she wants to keep the account.

Two retention rules often get confused. The Third Schedule’s 3-year retention window only applies to e-commerce entities with 2+ crore registered users in India, online gaming intermediaries with 50+ lakh users, and social media intermediaries with 2+ crore users — it is not a general 3-year rule for every business. Separately, Rule 8(3) sets a general 1-year minimum retention for logs and traffic data tied to security-safeguard obligations under Rule 6.

What a practical workflow needs

  1. One owner for intake
  2. Clear identity verification step
  3. System mapping for where data lives
  4. A response process and internal checklist

Common failure points

  • Support teams guessing instead of following SOPs
  • Analytics/CRM systems being forgotten
  • Manual work with no tracking trail

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