Sector wise readiness
Matrimonial and dating: delete account is not erasure
- Does a delete account button satisfy the erasure duty?
- Usually not. On a dating or matrimonial platform a person's data sits in the chats they had, the photos they sent and the profiles others saved. A delete that clears only the account record, while conversations and images live on, is the most common gap in the sector.
- Who this affects
- Dating, matrimonial and social platforms.
- What to do about it
- Ask where the person's data still exists after deletion, and whether you can actually reach it.
A misconception I keep seeing when matrimonial and dating platforms read DPDP checklists: "delete account is our erasure feature, that box is ticked."
It is not. On a dating or matrimonial platform, a person's data does not sit neatly in their own row. It is in the chats they had, the photos they sent, the profiles other users saved, the screenshots that left your system entirely.
Erasure has to reach across profiles, chats and photos. A delete button that only clears the account record, while the conversations and images live on, is the single most common gap in this sector. If someone withdraws, ask honestly: where does their data still exist, and can we actually reach it?
A sector map is a superset, not a launch checklist.
What applies from the start, whatever your size
- ✅ Notice
- ✅ Consent and easy withdrawal
- ✅ Security safeguards
- ✅ Rights handling
- ✅ Grievance mechanism
- ✅ Processor contracts
- ✅ Breach response
What this sector carries from day one
- ✅ Sensitive profile data. Relationship status, orientation and photos are among the most sensitive data anyone will hand you. Strong security and real minimisation, not just a privacy policy.
- ✅ Hard age assurance. Age gate so minors cannot be onboarded, absolutely. This is not a soft check. Minor access on a dating platform is the risk that ends companies.
- ✅ Granular consent for visibility. Consent has to be specific about what is shown to other users. "You agreed to our terms" does not cover who sees your photos.
- ✅ Full erasure. Across profiles, chats and photos. Not just the account row.
What may not apply yet
- ❌ SDF obligations. Large platforms are plausible candidates to assess, given sensitive relationship data at scale, but Significant Data Fiduciary status comes only on Government notification, not from user numbers.
- ❌ A mandatory Data Protection Officer, annual DPIAs and independent audits. These attach to SDF status once notified.
The better question
The better question is not "do we have a delete account button?"
It is "when someone leaves, does their data actually leave, and could a minor have got in at all?"
Law creates obligations. Scale and risk influence implementation. But sensitive data security, age assurance and real erasure apply from your first user. None of them wait for scale.
If you run a dating or matrimonial platform, does your erasure reach into chats and photos, or stop at the account?