SC-AI-035 · Content and platform

Takedown and response timelines

Medium effortCovered by ISO 27001: New for AISatisfies 5 obligations in 2 policies

What it means

  • Run a 24x7 process that removes or disables unlawful content within the legal clock, starting from when the order or complaint arrives.
  • Key Indian clocks under the IT Rules as amended in 2026:
    • 3 hours from a court order or a written, reasoned intimation from an authorised officer,
    • 2 hours from a complaint about content showing a person's private areas, nudity, sexual acts or impersonation including morphed images,
    • 36 hours to resolve complaints asking for removal of Rule 3(1)(b) content (some sub-clauses excepted),
    • 36 hours for reported deepfakes at SSMIs (per the 2023 advisory).
  • Act quickly on synthetic content violations found by your own monitoring too: remove, suspend the account without destroying evidence, and take the other required steps.
  • ISO 27001 reuse: None. New for AI, not covered by ISO 27001. Incident response tooling and on-call practices from ISO 27001 A.5.26 can be reused, but the obligation itself is a content law duty.

Why it matters

  • Missing these clocks risks losing safe harbour under Section 79 of the IT Act.
  • Two hours leaves no room for an inbox that is checked once a day; it needs on-call staff and tooling.
  • Victims of intimate deepfakes suffer harm by the minute.

Checklist

  1. Set up dedicated intake channels for government orders, court orders and user complaints, monitored 24x7.
  2. Configure ticket categories with SLA timers for 2, 3 and 36 hours; timer starts at receipt.
  3. Maintain an on-call roster with authority to remove content without waiting for senior sign-off.
  4. Build tooling to remove or geo-block content and all copies quickly, including re-uploads (SC-AI-034 Unlawful and prohibited content safeguards).
  5. Preserve removed content and related logs under legal hold (SC-AI-032 Logging and record keeping).
  6. Verify authorised officer intimations come from the right authority and are reasoned, without delaying action unduly.
  7. Notify the uploader where required and offer an appeal route (SC-AI-028 Customer grievance redressal for AI).
  8. Track SLA performance weekly; run root cause on every breach.
  9. Run a timed drill quarterly for the 2-hour and 3-hour clocks.

Evidence examples

  • Takedown SOP with the legal clocks and decision authority.
  • On-call roster and escalation contacts.
  • Ticket export showing receipt time, action time and SLA status.
  • Drill reports with measured response times.
  • Legal hold records for removed content.
  • SLA breach root cause analyses.

Common pitfalls

  • Clock measured from when someone reads the email, not from receipt.
  • Content removed from one URL but copies remain.
  • Evidence deleted with the content, hampering police investigation.
  • No weekend or night cover.

Satisfies

Standards crosswalk

Clause references only. Check the standard itself for the exact wording.

ISO/IEC 42001

  • 7.4 communication
  • A.8.3 external reporting

ISO/IEC 27001

No direct equivalent

SOC 2

No direct equivalent

Key takeaways

  • Know the clocks: 2 hours, 3 hours, 36 hours, all from receipt.
  • Meeting them needs 24x7 intake, on-call authority and fast tooling.
  • Remove content but keep evidence.

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