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TruPriv
Module 03

Data Governance

Find the personal data you hold, classify it, map where it flows, and hold it to a retention schedule that the system can act on. Runs standalone, and shares onboarding data with every other module.

The lifecycle

Six stages, from what you hold to what you have deleted.

  1. 01

    Discovery

    Scans locate personal data across databases, applications and platforms, including the copies nobody documented. The exports on a shared drive, the staging database restored from production two years ago, the spreadsheet a team keeps because the system does not do what they need. Those are the copies that turn a request into a fire drill.

  2. 02

    Classification

    Sec 2(t)

    The tool classifies what it finds, so the difference between a marketing list and a set of financial identifiers is visible without a manual review. Classification drives everything downstream: what safeguards apply, how long it may be kept, and whether a flow into a new system is routine or needs a decision.

  3. 03

    Mapping

    Sec 11(1)(a)

    A visual record of processing activities: what is held, where it lives, how it is used, and which departments and vendors it flows to. Each flow is tied to the purpose it serves, so a purpose that no longer exists is visible as data still moving for a reason nobody can name.

  4. 04

    Linking to consent

    Sec 6(10)

    Where a flow relies on consent, it is linked to the purpose in Module 1 rather than described separately. Two systems of record for the same fact will disagree eventually, and the disagreement surfaces at the worst moment: under a request, or under an audit.

  5. 05

    Retention

    Sec 8(7), Rule 8

    Every category carries a retention period and the basis for it. The schedule is a property of the data rather than a paragraph in a policy nobody reads, so the question of whether something should still be held has an answer the system can act on rather than one requiring a meeting.

  6. 06

    Erasure

    Sec 8(7)

    When consent is withdrawn or the purpose is served, erasure runs across every mapped location, including the copies outside the primary store, and each one acknowledges. An erasure that missed the warehouse copy is not an erasure, and the acknowledgements are what turn the claim into a record.

The processing record

One entry per flow, and the flow is the unit that matters.

The DPDP Act contains no Article 30-style obligation to maintain records of processing activities, and we are not going to invent one. Sec 11(1)(a)–(b) gives every Data Principal the right to a summary of their personal data and the identities of everyone it has been shared with, and Sec 10 imposes audits on Significant Data Fiduciaries. Neither is answerable without a maintained record.

So the record exists because two obligations require it in practice, not because a third one names it.

data_category
what it is, from the classification
location
system, database and field, including secondary copies
purpose_id
the purpose it is processed for
lawful_basis
consent, or the legitimate use relied on
recipients
departments, processors and vendors it flows to
retention_period
how long it may be held, and on what basis
erasure_state
scheduled, executed, acknowledged
last_seen
the scan that most recently observed it
Also inside Module 3

A map is only worth keeping if it stays true.

Sec 11(1)(a)–(b)

Rights requests become an export

A Data Principal is entitled to a summary of their personal data and the identities of everyone it has been shared with. If the map is current, that is a query. If it is not, it is a fortnight of asking colleagues what they hold.

Sec 10

Audit support

Significant Data Fiduciaries face audits and Data Protection Impact Assessments. Both start from an accurate picture of processing, which is why the DPIAs in Module 4 sit on these flows rather than on a description of them written from memory.

Drift is reported

A rescan that finds personal data in a system the map does not cover raises it. Estates do not stay mapped on their own; the useful property of a record is that it notices when it has stopped being true.