5. Lawful Basis for Processing
Under the DPDP Act, personal data is processed based on:
o
o
o
Employment-related purposes
Legitimate use by the employer
Consent, where explicitly required (e.g., optional learning programs, profile
enhancements)
6. Consent Management
Where consent is required:
o
o
o
Consent is obtained digitally through the LMS
Consent is specific, informed, and revocable
Withdrawal of consent may limit access to certain non-mandatory features
Mandatory trainings linked to employment or statutory compliance do not require
separate consent.
7. Data Sharing and Disclosure
Personal data is not sold, rented, or shared externally.
Data may be shared only with:
o
o
Authorized HR, L&D, IT, Compliance, and Audit teams
Approved LMS service providers acting as Data Processors, under contractual
confidentiality and DPDP compliance obligations
o
Statutory or regulatory authorities, when legally mandated
8. Data Retention
Personal and learning data is retained:
o
o
For the duration of employment, and
Thereafter as required for legal, audit, or compliance purposes
Upon completion of the retention period:
Data is securely deleted or anonymized
o
9. Data Security Safeguards
VCL & Data processor implements reasonable security safeguards including:
o
o
o
o
o
Role-based access control
Authentication and authorization mechanisms
Encryption of sensitive data
Secure hosting and backup controls
Periodic security reviews and access audits
10. Rights of Data Principals
In accordance with the DPDP Act, employees have the right to:
o
o
o
o
Access their personal data
Request correction or updating of inaccurate data
Seek grievance redressal
Nominate a representative (where applicable)
Requests can be raised through the contact details provided below.