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ARTICLE · 30 JANUARY 2025

Navigating Data Minimization Requirements Under India's DPDP Act

S&R Associates
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While the notification of provisions and rules under India's Digital Personal Data Protection Act, 2023 (the "DPDP Act") is awaited, organizations need to plan ahead.

IndiaPrivacy
Deborshi Barat
Deborshi Barat
Reshma (Vaidya) Gupte
Reshma (Vaidya) Gupte
Prakriti Anand
Prakriti Anand

Background

While the notification of provisions and rules under India's Digital Personal Data Protection Act, 2023 (the "DPDP Act") is awaited, organizations need to plan ahead (for an update on the DPDP Act and a roadmap for planning a long-term compliance strategy, see our notes here and here). Compliance planning strategies will need to consider the principles of legality, purpose/use limitation, data minimization, accuracy and storage limitation.

Data Minimization

The principle of data minimization involves limiting the collection, storage, processing and retention of personal data only to what is relevant and necessary for a specific purpose. A few practical examples of practices which may be contrary to principles of data minimization may include a recruitment agency seeking detailed information about the physical fitness of potential applicants, while inviting applications for an office/ desk job or a food delivery application retaining a customer's

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This insight/article is intended only as a general discussion of issues and is not intended for any solicitation of work. It should not be regarded as legal advice and no legal or business decision should be based on its content.

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