Legal Deadlines and Deleting Data — Explained Simply

7 October 2026. Two questions, answered in plain words:

  1. What are the legal deadlines, and how does Thnkrr meet them?
  2. Why can't we simply keep all data forever?

This is our reading of the laws, checked against the official texts. Our lawyer should confirm it before anything is published.


Part 1: Legal deadlines

What a "legal deadline" means

When someone complains about something on Thnkrr, for example a fake profile pretending to be them, the law says how fast we must act. If we're late, we can lose the legal protection that keeps a platform from being blamed for what its users post, and we can be fined.

Which laws, and when they apply

LawWhat it isApplies to us
TAKE IT DOWN Act (US)A 2025 US law: intimate images shared without consent must come down fastNow
US child-abuse reporting lawPlatforms must report child sexual abuse material to NCMEC, the US centre that receives these reportsNow
India's IT RulesIndia's rules for online platforms: complaint deadlines, court orders, intimate imagesOnce we have Indian users. We've built to them already, because they're the strictest and we'll need them later

The deadlines, and what Thnkrr does for each

SituationHow it reaches usDeadlineWhat Thnkrr does
Any complaintThe public complaint form (linked on every page)Acknowledge within 24 hoursThe complaint appears on the review list with a countdown. The person who complained sees the exact times we must answer by
Reported unlawful content (abuse, hate, sexual content and so on)The complaint form, or the "Report" button on any postDeal with it within 36 hoursShown with a countdown on the review list; turns red when late
An intimate image of someone, shared without consentThe dedicated removal form (no login needed)2 hours (the US law allows 48; India's rule is 2, so we use 2 for everyone)The team is emailed at once. The request goes to the top of the list. A safety case opens automatically, because on Thnkrr this could be a child. Once removed, every copy disappears within minutes, and the same picture can't be uploaded again
Someone pretending to be someone else, or a fake or edited picture of themThe complaint form ("someone is pretending to be me") or the Report button2 hoursTeam emailed at once; top of the list; countdown
A court order or government noticeArrives by email or the government's portal3 hours from when it reached usA reviewer logs it in the "Orders & notices" tab, with the time it arrived. Team emailed; countdown; recorded as done when the content is off
Every other complaintThe complaint formResolve within 7 daysCountdown on the list

Our own deadlines, stricter than the law

SituationOur deadlineWhy
A possible child-abuse caseConfirm within 4 hours, report to NCMEC within 24 hoursThe law says "as soon as reasonably possible"; we set firm numbers
A student who may be at risk of self-harm, referred to their schoolThe school acknowledges within 24 hours, or 1 hour if urgentSo a counsellor actually reaches the student

How it works day to day

  1. Something arrives through a form, a report or an email order.
  2. For anything on a 2- or 3-hour deadline, the team inbox is emailed immediately.
  3. It appears on the shared review list, sorted so the most urgent and the late items are at the top, with a countdown.
  4. A reviewer acts: removes the content, declines with a reason, or records the order as done.
  5. The person who complained sees the decision and our note on their status page.
  6. Everything is recorded in "Who did what": which reviewer, what they did, and when.
  7. If the time runs out, the item shows red as "overdue", and it's flagged on the dashboard.

Example: a parent reports an intimate photo of their child

  1. The parent fills in the removal form. No account is needed.
  2. Within seconds: the team is emailed, the request is at the top of the list with a 2-hour countdown, and a child-safety case opens.
  3. A reviewer finds the photo and removes it. Every copy is taken off within minutes, and that picture is blocked from being uploaded again.
  4. A locked copy is kept as evidence. Only the safety team can open it, and no reviewer can delete it.
  5. Vidhi, our Child Safety Lead, confirms the case within 4 hours. If it's child abuse, she reports it to NCMEC within 24 hours, and to the Indian police too if an Indian child is involved.
  6. The parent sees "removed" on their status page.

How the deadlines are enforced today

Here is exactly what Thnkrr has now to make sure a deadline isn't missed:

What's builtWhat it does
A clock on every itemThe moment a complaint, report or order arrives, its deadline is worked out and saved
One email to the team inboxSent at once for the three urgent kinds: intimate images, impersonation, and court or government orders. Only one email, and only once someone sets the team inbox address
Countdowns on the review screenEvery item shows how long is left, and turns red with "OVERDUE" when time runs out
Late items jump to the topThe review list puts anything past its deadline first
A "Deadlines" summary lineCounts how many of each kind are open, and how many are late
The complainant sees the deadlineTheir status page shows the exact time we must answer by
A record of who did what, and whenEvery action is logged with the reviewer's name and the time

What's missing. Today the system only works if someone is looking at the screen:

How LinkedIn and other companies do it

No company publishes its internal tools for this. What they do publish:

What they doExample
People working around the clockX says it has a team working 24 hours a day, 7 days a week, in every language it supports
A dedicated team for each kind of requestX has a team just for India's complaints. Meta sends court and government orders to its lawyers first
A named, published person in chargeLinkedIn names its India Grievance Officer, with an address and a web form. Its Indian court orders go to a separate email inbox at its law firm
Clear routes to escalateLinkedIn's reviewers can pass hard cases up to policy managers, who can ask the lawyers
The riskiest items firstMeta sorts its review list by how serious an item is, how fast it's spreading, and how likely it is to break the rules
Shared lists of known imagesFacebook, Instagram, Snap, TikTok, YouTube and others use NCMEC's "Take It Down" list, so a reported image is blocked everywhere
Publishing their speedLinkedIn says it decides a member's report in about 21 minutes (the middle figure) and confirms a government request in under an hour

What happens if a platform misses a deadline:

WhereWhat happens
IndiaThe platform loses its legal protection and can be held responsible for what users post. In 2021 the government said Twitter had lost it
US, intimate images (TAKE IT DOWN Act)Fines of up to $53,088 for each missed request. The US regulator (the FTC) began enforcing in May 2026 and has already written to platforms
US, child-abuse reportsKnowingly failing to report: fines of up to $600,000 the first time, and $850,000 after that

The big companies meet these deadlines with many people working around the clock and a clear chain of who does what. At our size, the same idea is one person on call who gets a phone call, and calls that move up the chain if nobody picks up.

What we recommend

Each item is marked US law now, India law later (once we have Indian users), or good practice.

  1. Someone is always on call. (Good practice, but the only way to meet a 2-hour deadline at night.)

    • Reviewers cover the day, roughly 7am to 11pm.
    • One reviewer is on call overnight and at weekends, taking turns week by week (one week in five each).
    • Vidhi, the Child Safety Lead, is always the second person called.
  2. A phone call or text for urgent items, not just email. (Good practice.) Intimate images, impersonation and government orders ring the on-call person's phone.

  3. Reminders that move up the chain. (Good practice.) For a 2-hour item:

    Time since it arrivedWhat happens
    0 minutesThe on-call reviewer is called
    30 minutes, nobody has picked it upCalled again
    60 minutesVidhi is called
    90 minutesThe engineering lead or founder is called

    For 3-hour orders, the same steps, spread out. For 24- and 36-hour items, a reminder at halfway and another 4 hours before the deadline.

  4. Hide first, check after, for intimate images. (Good practice.) When a properly filled-in removal request arrives, the image is hidden straight away, then a reviewer confirms it. If the request turns out to be false, the reviewer puts it back. Nobody waits for a person to wake up.

  5. Named people, published. (India law later, good practice now.)

    • The Grievance Officer's name and contact details on the site.
    • One named person responsible for all the deadlines.
    • A separate inbox for court and government orders that rings the on-call person.
  6. Join NCMEC's "Take It Down" list. (Good practice.) An image reported anywhere is blocked on Thnkrr too.

  7. A tracking number and full times for every request. (US law now.)

    • Every request gets a tracking number. We already give one.
    • We record when it arrived, when it was acknowledged and when it was acted on. Mostly built.
    • The "who did what" record can't be edited.
  8. Check how we're doing. (Good practice now, India law later.)

    • Every week, 15 minutes: how many deadlines we met or missed, and how fast we were.
    • Within 48 hours of any missed deadline: a short note on what went wrong and the fix.
    • Monthly: a summary in the same layout big platforms publish in India, so we're ready if it's ever required.

What this needs:

Also still needed


Part 2: Deleting data

The short answer

"Never delete" is not the standard, and for a platform for teenagers it isn't allowed in the long run:

So the real standard is keep while the account is in use, delete when there's a reason to, and keep only what the law requires after that.

What the law says we must KEEP

WhatHow longWhich lawApplies to us
Anything reported to NCMEC (child abuse)1 year after the reportUS child-abuse reporting lawNow
Content we removed180 daysIndia's IT RulesWith Indian users
Sign-up details of a closed account180 days after it closesIndia's IT RulesWith Indian users
System logs180 days, kept within India's reachCERT-In, India's cyber-security agencyWith Indian users
Personal data and activity logsAt least 1 year, even if the person deletes their accountIndia's data protection law (DPDP)From 13 May 2027
Anything linked to a lawsuit or police investigationUntil it's overGeneral legal dutyNow

What the law says we must DELETE, or can't keep forever

WhatWhenWhich lawApplies to us
A person's data, once it's no longer needed, or once consent is withdrawnAt that point, unless another law requires keeping itIndia's data protection law (DPDP)From 13 May 2027 (the government has proposed bringing it forward to November 2026, so check)
A person's data, when they askOn request, unless a law requires keeping itIndia's data protection lawFrom 13 May 2027
A school's student data, when the school asks or its contract endsWithin 60 daysThe standard US school data agreement (NDPA), which most US districts useAs soon as a school signs it
A student's data, when the school asksWhen askedCalifornia's student privacy law (SOPIPA)Now, for California schools (our lawyer to confirm)
Data of children under 13Only as long as needed; never forever; with a written policyThe US children's privacy law (COPPA)Only if an under-13 slips through. We don't allow them, so we delete at once
Data unused for 3 yearsWith a 48-hour warningIndia's data protection rulesNot us: only platforms with 20 million+ Indian users

What Thnkrr does today

What we recommend

  1. Keep everything while an account is in use.
  2. When an account is closed: hide it within 24 hours and delete it within 30 days, as LinkedIn does. Move only what the law requires into a locked store (removed content and sign-up details for 180 days, logs for a year, anything under a legal hold), and delete that automatically when the time is up.
  3. When a parent never gives consent, or withdraws it: delete after a short grace period.
  4. When a school asks, or its contract ends: offer students a copy of their own posts first, then delete that school's student data within 60 days and confirm it in writing.
  5. Accounts unused for a long time: pick one period, for example 3 years, with a warning first.
  6. Legal holds always win. Nothing under a child-safety case, police request or lawsuit is ever deleted until the hold ends.
  7. Write it all down as one "data retention schedule". Schools will ask for it, and the law requires one if we ever hold under-13 data.

Decisions needed (founder, with our lawyer)

  1. How long do we keep messages? Today there's no end date. This is the biggest open point.
  2. The inactivity period (point 5 above).
  3. Approve building "delete my account" and the steps above. They're needed before Indian users, or before the first school contract ends.
  4. Confirm the India start date with our lawyer: 13 May 2027, or earlier if the government brings it forward.

Sources: the US TAKE IT DOWN Act and the FTC's 2026 guidance and enforcement notice; LinkedIn's EU transparency report (August 2025) and India Grievance Officer page; Meta's and X's India monthly reports and Meta's content-review page; NCMEC's Take It Down participant list; the UK regulator Ofcom's code of practice (February 2025); 18 U.S.C. §2258A (US child-abuse reporting); India's IT Rules 2021 as amended in February 2026; CERT-In Directions 2022; India's DPDP Act 2023 and DPDP Rules 2025; the US COPPA Rule (16 CFR §312.10, as amended 2025); FERPA (34 CFR §99.31) and US Department of Education guidance; California's SOPIPA; the NDPA v2 school data agreement; LinkedIn's privacy policy; Facebook's Help Center. All checked 6–7 October 2026.

●  Have your own?

// Publish your own markdown.

Write your own
Legal Deadlines and Deleting Data — Explained Simply · DocHouse