Effective: July 2026 · ULTRA school private limited

Data Retention & Disposal Policy

Effective Date: 17 June 2026

Applicable to: All students (ages 3-8), parents/guardians, staff, and visitors of Ultra

1. Purpose

This Data Retention & Disposal Policy sets out how long undefined (“the School”) keeps different categories of personal data — collected on paper, in School systems, and through the Ultra Super App — and how that data is securely disposed of once it is no longer needed, in line with the Data Protection Policy and the DPDP Act, 2023.

2. Principles

3. Retention Schedule

Data Category

Retention Period

Disposal Method

Admission & enrollment documents (forms, ID/address proof, birth certificate)

Duration of enrollment + 5 years after the child leaves

Secure shredding (physical) / permanent deletion (digital)

Academic & attendance records, report cards

Duration of enrollment + 5 years (for transfer/reference requests)

Secure shredding / permanent deletion

Health, medical & allergy records

Duration of enrollment + 3 years

Secure shredding / permanent deletion

Photographs & videos (internal use)

Duration of enrollment + 2 years, or until no longer needed for records

Permanent deletion from internal drives/App

Photographs & videos (public — website/social media)

Until consent is withdrawn or the content is no longer current, reviewed at least annually

Removal from live site/social channel; cannot recall third-party shares

CCTV footage

30–90 days, unless required longer for an active investigation

Automatic overwrite / secure deletion

Fee & financial records

8 years (statutory/accounting requirement)

Secure shredding / permanent deletion

Staff HR & recruitment records (incl. background verification)

Duration of employment + 5 years

Secure shredding / permanent deletion

POSH / grievance / safeguarding complaint records

8 years, or longer if a legal matter is pending

Restricted-access secure storage, then secure deletion

Ultra Super App account data, chat/communication logs, login activity

Duration of active account + 1 year after account closure

Permanent deletion by vendor per Data Processing Agreement

Payment transaction references (excluding full card/bank details)

8 years (statutory/accounting requirement)

Secure deletion

Consent records (admission, photo/media, App onboarding)

Duration of enrollment/employment + 5 years (evidence of compliance)

Secure shredding / permanent deletion

4. Backups

Where data is backed up (including App vendor backups), backup copies are subject to the same retention limits and are purged or overwritten on a rolling basis consistent with this schedule, except where a longer backup-cycle is technically unavoidable, in which case access to expired data within backups is restricted.

5. Early Deletion Requests

A Parent or staff member may request earlier deletion of specific personal data (e.g., withdrawal of photo consent) by contacting the Data Protection Officer: [Data Protection Officer / Grievance Officer Name], [dpo@ultraschool.in], +91 81369 46055. Such requests are honored unless the School has a legal obligation or legitimate administrative need to retain the data for the period specified above.

6. Responsibility

The Principal/School Administrator, supported by the Data Protection Officer, is responsible for ensuring records (physical and digital, including on the App) are reviewed periodically and disposed of in line with this schedule, and for instructing the App vendor and other processors to do the same under their Data Processing Agreements.

7. Review

This Policy is reviewed annually alongside the Data Protection Policy.