GRC Services › Data Retention Policy
Data Retention Policy — Keep what you need, delete what you don't
SIRI Security designs data retention policies that balance legal retention obligations, genuine business need, and the privacy risk of holding data longer than necessary — then helps you actually implement deletion.
62%Of cloud detections
6 HRCERT-In notification window
29.44LIncidents CERT-In handled
Why GRC is now a named line item for boards
Live tracking · scroll to see every relevant change
Effective
31 JUL 2026
RBI's 2026 Framework expects a structured risk-management approach, not point-in-time compliance checks — the core discipline GRC services are built to operationalise.
Named requirement
SEBI CSCRF
SEBI's framework layers its own risk and reporting obligations on regulated intermediaries, on top of general GRC practice.
Named requirement
DPDPA
India's Digital Personal Data Protection Act expects demonstrable data-risk governance, including third-party and vendor risk.
Baseline
6 HR WINDOW
CERT-In's notification requirement makes risk visibility a precondition, not an afterthought, for meeting the deadline.
Underwriting standard
CYBER INSURANCE
Cyber insurers increasingly verify represented controls before binding or renewing cover — a gap between claimed and actual posture directly affects a claim.
Risk management the board can act on, not a spreadsheet nobody updates
What does Data Retention Policy work involve?
Most organisations retain data far longer than legally required or practically useful, simply because nobody decided otherwise — which increases breach impact and complicates privacy compliance without any corresponding benefit.
We work through your data categories against actual legal retention requirements and genuine business need, produce a clear retention schedule, and help implement the technical deletion or archival process that makes the policy real rather than aspirational.
Third-party risk is often the largest unmanaged exposure
Vendor and third-party relationships routinely carry as much data and system access as internal teams — without a formal TPRM programme, that risk is invisible until it becomes an incident.
SIRI Security delivers Data Retention Policy to this standard directly — practitioner-led, documented, and connected to SIRI Law LLP's legal and regulatory response if a finding ever needs to go further.
What organisations get wrong
Four assumptions that leave GRC programmes underdeveloped
Most GRC gaps aren't about missing effort — they're about risk that was never formally registered in the first place.
01 — VISIBILITY
“We track risk informally, and that's enough”
An informal risk list rarely survives a board or auditor request for a structured, prioritised, and owned risk register.
02 — SCOPE
“Our vendors are covered by their own security teams”
Third-party risk sits with you contractually and reputationally regardless of a vendor's own internal security posture.
03 — INSURANCE
“Our cyber insurance policy will cover a real incident”
Insurers verify represented controls at claim time — gaps between what was declared and what's actually implemented can directly affect a payout.
04 — RETENTION
“We keep data indefinitely just in case”
Undefined data retention is itself a growing regulatory and breach-exposure risk under DPDPA, not a neutral default.
What Data Retention Policy covers
What's included, start to finish
A working GRC programme, not a one-time framework document.
01
Data category & retention requirement mapping
What you hold, and what legal obligation (if any) actually requires you to keep it.
02
Retention schedule design
Clear, specific retention periods per data category, not a vague 'as needed' policy.
03
Deletion/archival process design
How retention limits actually get enforced technically, not just documented.
04
Legal hold process
How retention rules pause appropriately during litigation or investigation.
05
Policy documentation & rollout
The written policy plus support rolling it out to the teams who generate and hold the data.
Evidence, not guesswork
No formal GRC vs. informal effort vs. a SIRI-supported programme
The gap surfaces at renewal, at audit, or at claim time — exactly when it's most expensive to discover.
| Approach | No formal programme | Informal / ad hoc | SIRI Data Retention Policy |
|---|---|---|---|
| Risk register | None | Informal list | Structured, owned, reviewed |
| Third-party risk assessment | No | Rare | Standard |
| Insurance-readiness verification | No | Assumed | Assessed directly |
| Regulatory alignment (RBI/SEBI/DPDPA) | No | Assumed | Assessed directly |
| Board-level reporting cadence | No | Irregular | Recurring |
Sources: RBI (Commercial Banks — Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026; SEBI Cybersecurity and Cyber Resilience Framework (CSCRF); Digital Personal Data Protection Act, 2023. Summarised for comparison.
Numbers every board should know
What a GRC programme is actually protecting against
62%
Of cloud detections
Trace to misconfiguration and IAM exploitation (DSCI) — often a third-party or vendor-access issue.
6 HR
CERT-In notification window
Depends on risk visibility already existing before an incident starts the clock.
29.44L
Incidents CERT-In handled
In the latest reporting year — the backdrop cyber insurance underwriting is increasingly priced against.
70%
Of malware detections
Are trojans and file infectors (Seqrite 2026).
Why SIRI for Data Retention Policy specifically
GRC built by the team that also negotiates the fallout
The same practice that builds your risk register and vendor assessments handles the regulatory and contractual fallout if a risk materialises.
01
Programmes built by SIRI's GRC and Compliance lead
Sneha Iyer, Associate Partner and Head of GRC and Compliance, has delivered ISO 27001, SOC 2, and SEBI CSCRF programmes across the client base this catalogue serves.
02
Financial-sector risk obligations covered directly
Deepa Menon, Senior Associate, advises banks, NBFCs, and payment aggregators directly on RBI licensing, SEBI CSCRF, and financial-sector cyber resilience.
03
Findings connected directly to legal exposure
SIRI Security runs under the same roof as SIRI Law LLP — when a finding carries real legal exposure, the engagement can be brought under attorney-client privilege from day one, not bolted on after the fact.
04
Technical risk verified, not self-reported
Vikram Rao, SIRI's Head of Cybersecurity, directs offensive security and incident response and leads CERT-In breach containment for enterprise clients.
Who this is built for
Organisations this GRC service is built for
Banks, NBFCs & insurers
Organisations with significant vendor networks
Companies renewing cyber insurance
SEBI-regulated intermediaries
Boards needing a defensible risk register
How we work
From scoping to ongoing delivery
01
Current-State Assessment
We assess where you actually stand today, not against a generic template.
Week 102
Framework & Process Design
We design the specific process, register, or framework your organisation needs — sized to your risk, not oversized.
Weeks 2–303
Implementation Support
We help implement the process with your team, so it survives after we leave, not just on paper.
Week 4+04
Review & Continuous Improvement
Periodic review keeps the programme current as your risk and regulatory landscape change.
OngoingFrequently asked
Data Retention Policy, answered directly
Does this help reduce our breach impact if something goes wrong?
Yes — data you no longer hold can't be exposed in a breach, which is one of the most effective and underused risk-reduction levers available.
How does this interact with DPDPA/GDPR purpose limitation?
Directly — this policy is a core control for satisfying the storage/purpose limitation principle both frameworks require.
How long does this take?
Most GRC engagements in this category run 3 to 8 weeks depending on organisational size and current maturity.
Who runs this day to day?
A senior SIRI Security GRC consultant leads the engagement, with SIRI Law LLP input wherever a finding has legal or regulatory weight.
Put risk on the record
Scope Data Retention Policy.
Most engagements start with a current-state risk review before building out the full programme.
Talk to SIRI Security: +91 79819 12046
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