Is my data private with a research analyst?
The short answer. SEBI's Investor Charter requires protection of confidential client information. It allows disclosure for legal obligations or with the client's specific consent. Privacy also has to work alongside recordkeeping: the rules require service-interaction records to be retained.
Published 11 November 2026 · Potoos Research Services
What the privacy duty covers
Confidential information means private information shared in the service relationship. Consent means your permission. The Investor Charter, section C, requires protection against unauthorised use and confidentiality, with exceptions for legal obligations or specific consent to sharing. Section E of the same charter lists a right to privacy and confidentiality among the investor's rights.
Before joining, read the privacy policy and ask which information is collected, why it is needed, who can access it and how to raise a privacy query. These are practical checks to make the provider's process clear.
Why records may remain after the service ends
Retention means keeping a record. Regulation 25(2) requires the specified records to be preserved for at least five years.
SEBI's 23 October 2026 circular says these records cover every conversation about the research service, from the first interaction until the service is complete. They can be signed paper records, call recordings, emails from your registered email ID, SMS records or any other legally verifiable record. They cover prospective clients too, meaning people discussing the service before joining. The circular says the purpose is to document the interaction so that a later complaint about the research service can be looked into.
The same circular requires longer preservation when a dispute is unresolved or SEBI directs that particular records be kept. Ending a subscription therefore does not mean every required record can immediately be erased.
What the recent call-recording change means
The October circular says call recordings are no longer mandatory for clients who are institutional investors. These are investing organisations, such as insurance companies and pension funds, as explained in SEBI's glossary. The exception is limited to that named category.
The circular is dated 23 October 2026 and says it takes effect from 8 November 2026. The matching change to regulation 25(1)(vii) is marked in SEBI's updated regulations as in force from 9 November 2026.
The circular also repeats that a call recording is not needed when the interaction happens through a medium such as email that already leaves a digital record. A digital record is a stored copy of the communication, such as the email itself.
The exception covers call recordings only, and only for institutional clients. For an individual investor nothing changes: the provider still keeps records of its service conversations with you, including call recordings where the conversation is by phone. Ask the provider how it records and protects those communications.
Where to check Potoos's process
Read Potoos's published privacy policy and ask about anything that is unclear before sending documents.
Sources
- SEBI Investor Charter for Research Analysts. 2 June 2025. PDF page 4, section C, data privacy and confidentiality bullets; page 5, section E, right to privacy and confidentiality.
- SEBI Research Analysts Regulations. Updated 10 October 2026. PDF page 21, regulation 25(1)(vii) and its proviso, regulation 25(2), footnote 51 (in force 9 November 2026).
- SEBI circular on client call records. 23 October 2026. PDF pages 2-3, paragraphs 4.1 and 4.2; page 3, paragraph 6 (effective 8 November 2026).
- SEBI glossary of capital-market terms. Undated; checked 10 November 2026 PDF page 38, Institutional Investors entry.
- Potoos privacy policy. Checked 10 November 2026. Linked for reading; its contents are not summarised here.
Sources checked on 10 November 2026. Information cutoff: 10 November 2026, 19:00 IST
Common questions
Does cancelling immediately erase all records?
No. The required records have a minimum five-year retention rule, with longer preservation in the specified dispute or regulatory situations.
Do the interaction rules include people who have not joined?
Yes. Regulation 25(1)(vii) and the October circular both cover prospective clients, meaning people who have had a conversation about the research service before joining.
Does an email interaction require a call recording?
No. The October circular says a call recording is not needed for an interaction through email or another medium that leaves a digital record.
Potoos Research, SEBI-registered Research Analyst. Registration number INH000027380. SEBI is the Securities and Exchange Board of India.