RETENTION GOVERNANCE

Data Retention & Disposal Policy

Retention schedules, storage minimization, and cryptographic disposal standards for patient dossiers, invoices, and communication logs.

Effective Date: March 2026 • Jurisdiction: India (DPDP Act) • Global Framework • Status: Active & Legally Binding

1. Principle of Data Minimization

Nirogyam retains personal and medical data only for as long as strictly necessary to fulfill the facilitation purpose for which it was gathered, or to comply with statutory legal, accounting, and reporting obligations.

2. Specific Retention Schedules

Active Journey Dossiers: Retained for the duration of the medical travel journey plus 180 days post-discharge to support follow-up teleconsultations.
Financial & Invoicing Records: Retained for 7 years pursuant to Indian tax and corporate statutory requirements.
Consent Logs & Audit Trails: Retained for 3 years to demonstrate regulatory compliance under DPDP Act and GDPR.

3. Secure Cryptographic Disposal

Upon expiry of the designated retention period, records stored in Cloudflare D1 and R2 object storage are cryptographically erased and overwritten, rendering recovery impossible.

Controlling Language: In the event of any conflict or inconsistency between translated language versions of this document, the official English language version shall strictly govern and control.

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