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ARTICLE · 14 JANUARY 2026

Implementing DPDPA In Banking: From Legal Text To Live Systems

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For the last year, Digital Personal Data Protection Act, 2023 ("DPDPA/Act") functioned largely as a conceptual privacy framework, important in principle but lacking operational specificity.

IndiaPrivacy
Vara Gaur
Vara Gaur
Sakina Kapadia
Sakina Kapadia
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For the last year, Digital Personal Data Protection Act, 2023 ("DPDPA/Act") functioned largely as a conceptual privacy framework, important in principle but lacking operational specificity. Institutions observed it cautiously, debated theoretical interpretations, and waited for "clarity." That era is over.

The Indian financial sector has, over the last few years, seen multiple publicly reported incidents involving unauthorised access, data leakage and misuse of customer information. In several cases, these incidents have not stemmed from sophisticated external attacks alone, but from weaknesses in vendor access controls, legacy systems, misconfigured databases or excessive internal data access. These incidents have resulted in financial loss, customer harm, regulatory scrutiny and reputational damage.1

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