Data Storage Policy
- To maintain effective data governance, all institutional data is classified based on its sensitivity, regulatory requirements, and the risk associated with its unauthorized access or disclosure. This classification system is essential for determining appropriate retention periods, storage methods, and disposal procedures.
- Institutional data must be stored in secure repositories that are appropriate for the sensitivity of the information. Backup processes must be implemented to ensure data availability and business continuity in case of system failure, data loss, or disasters. Backup data should be encrypted and stored in a secure offsite location or on cloud platforms that comply with industry standards.
- Archived data must be indexed and stored in long-term, tamper-proof systems. Access controls should be applied to ensure only authorized personnel can retrieve archived data. Archival must follow retention timelines defined for each classification tier (e.g., confidential, internal, public).
- When institutional data is no longer required for operational or compliance purposes, it must be securely disposed of. Disposal methods may include digital shredding, degaussing, or physical destruction of storage media.
- Unneeded, non-authoritative data—including outdated files, duplicate records, and files not tied to business purposes—must be periodically reviewed and purged. Purging reduces the risk of unintentional exposure, conserves IT infrastructure resources, and strengthens overall data security posture.
- Our handling of customer data is guided by a privacy-first approach and is subject to both internal governance policies and external regulatory requirements.
- All personal data is collected directly from the customer during application processes, service interactions, or onboarding workflows. No personal information is accessed, used, or shared without the customer’s explicit consent, particularly in the case of sensitive data such as credit reports.
- We obtain and retain credit report data from Equifax for a fixed period of six (6) months. This data is only collected after explicit and informed consent is granted by the customer, and it is used solely for the purposes defined during consent collection (e.g., creditworthiness assessment, risk scoring). After the retention period expires, credit report data is securely purged unless continued retention is mandated by legal obligations.
- We retain all customer profile data indefinitely unless a deletion request is received from the customer. This data includes, but is not limited to: Full Name, Mobile Number, Date of Birth, Pincode, PAN (Permanent Account Number), Application-related inputs and identifiers. This permanent retention allows us to offer continuous service, maintain user histories, comply with audit trails, and fulfill regulatory reporting obligations.
- Customers have the right to request the deletion of their personal data, including credit report information. Upon receiving a formal request and verifying the identity of the requestor, we initiate a secure deletion process for all personal and credit-related data. Note: While customer data can be erased, certain logs and transactional metadata (e.g., system-generated logs, lead generation records, or sales records) are excluded from deletion. These records are retained for legal, compliance, audit, and operational purposes.
Specific Provisions: Data on Protected Storage
- ● Data (Protected Confidential) will be stored only in approved locations and on approved equipment or storage facilities.
- ● On-roll employees should refrain from making duplicate copies or shadow files of authoritative data resources.
- ● Temporary duplicate copies of electronic data created for legitimate reasons must be protected in a like manner to the authoritative data, and removed in a timely manner.
- ● Standards for storing electronic data containing sensitive data should be created and periodically reviewed.
- ● Standards for storing hardcopy containing sensitive data should be created and periodically reviewed.
- ● Periodic reviews should be performed by Security Assurance to ensure compliance with data management policies, standards, and procedures.
Data Backups and Off-site Storage
- ● All data located on our own IT Resources will be backed-up on a regular basis consistent with data classification standards applicable to the data being backed-up.
- ● Backups of data whose loss would impact the operation or viability of the company confidential matters will be taken off-site or written off-site to a secure location in a timely manner.
- ● Any backup media containing confidential data taken off-site or backup data sent off-site will be encrypted.
Data Storage
- ● The need to retain data in locations will be reviewed on an ongoing basis.
- ● Data no longer needed for routine operations, but which must be retained, will be archived in a timely manner.
- ● The management & IT supervisor representative will develop criteria for deciding when data can be archived.
- ● They will also develop procedures for archiving of data.
Data Retention
- ● Data Stewards and Data Managers will be knowledgeable about standards, and procedures regarding retention of data.
- ● Data Managers & Record Retention Specialists will develop procedures to ensure that required data is always accessible, especially as backup media ages, previously supported media is discontinued, supported data formats and standards change, and security controls change.
Data Disposal
- ● The need to retain operational and archived data will be reviewed on an ongoing basis.
- ● Data no longer needed for routine operations and which need not be retained in an archive will be destroyed in a timely manner.
- ● Archived data which need no longer be retained will be destroyed in a timely manner in compliance with State record retention policies.
- ● Data managers in collaboration with functional Record Retention Specialists will develop procedures for disposing of data in compliance with monthly & yearly record retention schedules.
IMPORTANT ADDITIONAL GUIDELINES
- ● Data is stored on paper, it should be kept in a secure place where unauthorized people cannot access it.
- ● These guidelines also apply to data that is usually stored electronically but has been printed out for some reason.
- ● People should make sure paper and printouts are not left where unauthorized people could see them, like on a printer.
- ● Printouts should be shredded and disposed of securely.
- ● When data is stored electronically, it must be protected from unauthorized access, accidental deletion, and malicious hacking attempts.
- ● Data should be protected by AD passwords that are changed on a periodic basis and never shared between employees.
- ● If data is stored on removable media, these should be kept locked away securely when not being used.
- ● Data should only be stored on designated drives and servers.
- ● Servers containing personal data should be sited in a secure location.
- ● Data should be backed up frequently- the backups should be tested regularly, in line with the company’s standard backup procedures-i.e. either in authorized shared drives which can be accessed via company LAN or VPN or on One Drive.
- ● All servers and computers containing data should be protected by approved security software and firewalls.
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More About GroMo
About GroMo
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