DPDP for the Customer service department in BFSI

Under PMLA and RBI's KYC Master Direction, keep identity records for at least five years after the relationship ends, and transaction records for at least five years from the transaction. During that time, keep them only for that legal purpose. After it, erase or anonymise unless another law requires more.

Section 8(7) allows retention where a law requires it. PMLA and RBI's KYC rules are such laws. Section 8(7) · Rule 8 · Section 7

1. List KYC and transaction record types.
2. Set the start date: end of relationship or date of transaction.
3. Restrict access to closed-account records.
4. Erase or anonymise after the period.
5. Explain this in erasure replies.

• Retention schedule
• Access restrictions on closed accounts
• Deletion logs

• Keeping everything for ever
• Deleting before the legal period
• Using closed-account data for marketing

• How long can we keep personal data?
• Someone asks us to delete their data. Must we?
• Does deletion have to reach backups and test copies?

Collection agents act for you, so you are responsible for what they do. They should get only the data needed to contact the borrower, use it only for collection, and never share the debt with family, friends or employers. RBI's rules on recovery conduct, including calling hours, apply alongside DPDP.

Section 8(1) and 8(2) make you responsible for processors. Section 8(5) needs safeguards. Section 8(1)–(2) · Section 8(5) · Rule 6 · Section 6

1. Share only name, contact details and the amount due.
2. Put data terms and conduct rules in every agency contract.
3. Record calls and review a sample.
4. Ban use of the borrower's phone contacts.
5. Take back or delete data when the account closes.

• Agency contracts
• Call review records
• Data return certificates

• Sending full loan files to agencies
• Agents calling relatives
• No deletion after the account closes

• What must a vendor contract say about personal data?
• What about call recordings and customer service screens?
• How do we handle a privacy complaint within 90 days?

Send a summary of the personal data you hold about them and what you do with it, and the names of the other organisations you shared it with and what was shared. Check the person's identity first, log the request and keep a copy of your reply.

The summary should list partner insurers, credit bureaus and collection agencies that received data.

Section 11 gives the right to a summary and the list of organisations it was shared with. Rule 14 asks you to publish how requests are made and to answer within the period you publish. Sections 11–14 · Rule 14 · Section 8(9)–(10) · Rules 9, 14

1. Log the request in one register the day it arrives.
2. Verify identity using details you already hold.
3. Search every system, including vendors' copies.
4. Write a plain summary: what data, why it is used, who received it.
5. Send it, and file the request, search notes and reply.

• Request register
• Search notes for each request
• Copy of each reply with date

• Sending raw database dumps
• Forgetting data held by vendors
• No identity check before sending

• How do we handle a privacy complaint within 90 days?
• Someone asks us to delete their data. Must we?
• Where does personal data live in our organisation?

Publish one clear way to complain, log every complaint, give it an owner and reply within the period you publish, never more than 90 days. People can go to the Data Protection Board only after using your process, so a good process keeps most matters with you.

A privacy complaint may also reach the RBI Ombudsman. One log, tagged for both, avoids two different answers.

Section 8(10) requires a working grievance process. Rule 14(3) caps the reply time at 90 days. Section 13 says people must use your process before approaching the Board. Section 8(9)–(10) · Rules 9, 14 · Sections 11–14 · Rule 14 · Sections 18–26

1. Publish one contact for privacy complaints on your website, app and notices.
2. Log each complaint with the date, channel and a named owner.
3. Acknowledge within a few days, and set an internal target well under 90 days.
4. Find and fix the cause, not just the single case.
5. Reply in writing and close the entry with the date.

• Complaint register with dates
• Replies sent
• Monthly summary to management

• Mixing privacy complaints into general complaints with no tag
• No owner, so nobody counts the days
• Closing a complaint without fixing the cause

• Someone asks what data we hold about them. What do we send?
• Someone asks us to delete their data. Must we?
• Someone withdraws consent. What has to stop, and how fast?

Call recordings, chat transcripts and agent screens hold a lot of personal data. Tell callers that calls are recorded and why, keep recordings for a set period, limit who can listen, and mask card numbers and passwords on screen and in recordings.

Never record card numbers or OTPs. Pause recording when customers read them out.

Section 5 needs notice, Section 8(5) needs safeguards, and Section 8(7) needs erasure after the purpose. Section 5 · Rule 3 · Section 8(5) · Rule 6 · Section 8(7) · Rule 8

1. Play a short recording notice at the start of calls.
2. Set a retention period by call type.
3. Pause recording when card or other sensitive details are given.
4. Limit replay rights to quality and complaint teams.
5. Lock agent screens and stop phones on the floor if data is sensitive.

• Recording notice script
• Retention settings
• Replay access list

• Recordings kept indefinitely
• Card numbers in recordings
• Open replay access for all supervisors

• How long can we keep personal data?
• Who should be able to see personal data in our systems?
• How do we handle a privacy complaint within 90 days?

You must erase data that you no longer need for the purpose it was collected for, unless a law requires you to keep it. Where a law does require it, keep the data, stop using it for anything else, and tell the person why it is being kept and until when.

Closed-account KYC and transaction records stay for the PMLA period; offers and profiling stop at once.

Section 12 gives the right to correction and erasure. Section 8(7) allows retention only where a law requires it. Rule 8(3) asks every organisation to keep personal data and logs for at least one year first. Sections 11–14 · Rule 14 · Section 8(7) · Rule 8

1. Log the request and verify identity.
2. Check the retention schedule for each record type involved.
3. Delete what has no legal reason to stay, including copies with vendors and in test systems.
4. Mark what must stay, with the law and the end date.
5. Reply in plain words: what was deleted, what is kept, why and until when.

• Erasure log
• Vendor deletion confirmations
• Reply to the person

• Refusing every erasure request 'because of backups'
• Deleting records a law requires
• Not telling vendors

• How long can we keep personal data?
• Does deletion have to reach backups and test copies?
• Someone asks what data we hold about them. What do we send?

Withdrawal must be as easy as giving consent. Once someone withdraws, you and every vendor working for you must stop that use within a reasonable time. What was done before withdrawal stays lawful, and data that a law requires you to keep is kept.

A customer taps 'stop offers' in the app. The dialler, SMS tool and partner insurer must all stop within a day.

Section 6(4) to 6(6) give the right to withdraw at any time, with the same ease, and require processors to stop as well. Section 8(7) then asks for erasure unless a law requires retention. Section 6 · Section 8(7) · Rule 8 · Section 8(1)–(2)

1. Give one simple way to withdraw on every channel where consent is taken.
2. Record the withdrawal against the person and the purpose.
3. Push the change to every system and vendor that uses that purpose.
4. Confirm to the person, in writing, what has stopped and what is kept by law.
5. Check a sample every month to see that the change actually reached every list.

• Withdrawal log with time stamps
• Proof that downstream systems and vendors updated
• Confirmation sent to the person

• Withdrawal by email only, while consent was one tap in an app
• Stopping in the main system but not in vendor lists
• Deleting records a law requires you to keep

• When do we need consent, and when can we rely on a legitimate use?
• Someone asks us to delete their data. Must we?
• What must a vendor contract say about personal data?

Sending personal data to the wrong chat or a personal account is one of the most common breaches. Banning messaging rarely works. Give staff an approved tool that is easy to use, set simple rules, and make it safe to report a wrong send at once.

Relationship managers share lead lists and statements on chat. Give them a CRM route.

Section 8(5) asks for reasonable safeguards. A wrong send is a breach under Section 2(u), and Section 8(6) applies. Section 8(5) · Rule 6 · Section 8(6) · Rule 7

1. Ask teams how they actually share files and photos today.
2. Provide an approved tool for that job.
3. Set three simple rules: approved tool, no personal accounts, report wrong sends.
4. Teach the rules with real examples from your own work.
5. Treat a quick report as good behaviour, not a disciplinary case.

• Approved-tool policy
• Training record
• Incident reports of wrong sends

• A ban with no alternative
• Punishing people who report
• Ignoring group chats with vendors

• Something has gone wrong. What happens in the first 72 hours?
• Who needs DPDP training, and what should it cover?
• Who should be able to see personal data in our systems?