Purpose
This Policy establishes the rules governing the retention, archival, anonymization, restoration, and permanent deletion of information processed through SiriON. It supports compliance with the Digital Personal Data Protection Act, 2023 and Digital Personal Data Protection Rules, 2025, implements data minimization principles, prevents unnecessary storage of personal information, and defines retention obligations for clinical, academic, security, and operational records.
Principles
SiriON retains information only for legitimate operational, healthcare documentation, academic documentation, security, regulatory compliance, fraud prevention, or legal purposes. Information shall not be retained indefinitely without a legitimate purpose, and where retention is no longer necessary, information shall be deleted, anonymized, or irreversibly destroyed.
Data Categories
Data is categorized into account information, clinical documentation, clinical media, academic records, compliance records, and security records.
Schedule
Account information is retained for the duration of the active account plus 30 days after deletion request. Clinical documentation and clinical media are retained for the duration of active use and any applicable legal, institutional, academic, or professional retention obligations. Academic logbooks are retained for the duration of the active account plus 3 years unless earlier deleted by the User. Consent records are retained for the active relationship plus 2 years after withdrawal or account closure. Legal acceptance records are retained for the active relationship plus 3 years after account closure. Security logs, authentication logs, and synchronization logs are retained for a minimum of 1 year. Incident response records are retained for a minimum of 3 years after incident closure. Audit records are retained for a minimum of 3 years after creation. Backup copies follow a rolling encrypted lifecycle not exceeding operational necessity.
Deletion
Users may withdraw consent by deleting their SiriON account. Upon account deletion, access to SiriON services terminates, future processing ceases except where retention remains necessary, eligible information enters the deletion workflow, and certain records may continue to be retained for security, compliance, fraud prevention, audit, legal, and regulatory purposes.
Soft Delete
Where deletion is requested, the record is marked as deleted, the deleted_at timestamp is stored, the information enters a temporary restoration period, and following expiry of the hold period it becomes eligible for permanent deletion.
Pre-Erasure Notice
Where SiriON performs automated deletion of information due to inactivity, retention expiry, or account closure, SiriON may provide advance notice before permanent erasure. Where technically feasible, notice shall be provided at least forty-eight hours before irreversible deletion and may be delivered through in-app notifications, email, SMS, or WhatsApp.
Legal Hold
SiriON may suspend deletion where information is reasonably required for regulatory investigations, DPDP Board proceedings, court proceedings, arbitration proceedings, fraud investigations, security investigations, contractual disputes, or enforcement of legal rights. Deletion resumes once the legal hold is lifted.
Permanent Erasure
Permanent erasure may include database deletion, cryptographic destruction of encryption keys, secure removal from storage buckets, backup expiration, metadata removal, and removal from synchronization queues. SiriON takes reasonable measures to ensure deleted information cannot be reconstructed through ordinary means.
Backups
Encrypted backups may continue to contain deleted information for limited periods until backup rotation cycles expire. Backups are maintained solely for disaster recovery, business continuity, and security restoration, and shall not be used to restore deleted information except where legally required.
Security Logs
Security-related logs including authentication events, access records, synchronization records, file access logs, and administrative actions are retained for a minimum of one year in accordance with applicable legal requirements and security obligations.
Incident Records
Records relating to security incidents, data breaches, unauthorized access, forensic investigations, and regulatory reporting are retained for not less than three years after closure of the incident.
Anonymization
Where operationally feasible, SiriON may anonymize information instead of deleting it. Anonymized information may be retained for product improvement, usage analytics, service quality metrics, and statistical reporting, and shall not reasonably identify any individual.
Policy Review
This Policy is reviewed at least annually and may be revised to reflect changes in law, regulatory guidance, security requirements, platform functionality, or healthcare compliance requirements.
Contact
Questions regarding retention, deletion, or erasure may be directed to the Privacy & Compliance Team at SiriON Health via privacy@sirionhealth.com.