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ARTICLE · 15 SEPTEMBER 2026

How Does The DPDP Act Regulate AI Training And Automated Decision-Making In India

King, Stubb & Kasiva
King, Stubb & Kasiva
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King, Stubb & Kasiva

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The rapid adoption of artificial intelligence (“AI”) has brought data protection considerations into the design, training and deployment of AI systems. AI models may be trained using datasets containing names, images, text, identifiers, behavioural information or other data that can relate to identifiable individuals. AI systems may also process personal data when they are deployed for purposes such as recruitment, credit assessment, insurance, healthcare, customer profiling or content moderation.

IndiaPrivacy
Dhruv Kaushal
Dhruv Kaushal
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Introduction

The rapid adoption of artificial intelligence (“AI”) has brought data protection considerations into the design, training and deployment of AI systems. AI models may be trained using datasets containing names, images, text, identifiers, behavioural information or other data that can relate to identifiable individuals. AI systems may also process personal data when they are deployed for purposes such as recruitment, credit assessment, insurance, healthcare, customer profiling or content moderation.

This raises two important questions: Does India’s Digital Personal Data Protection Act, 2023 (“DPDP Act”) apply to AI training? And what does it require when AI systems are used to make decisions affecting individuals?

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