Understanding the road ahead—even before the law is enforced.
Introduction: A Turning Point for Data and Identity in India
India’s Digital Personal Data Protection (DPDP) Act, 2023 is a landmark privacy legislation aimed at regulating how personal data is collected, stored, and shared. Although the law has been passed, it is not yet enforced, leaving digital businesses—especially those handling identity—at a critical moment of preparation and anticipation.
For digital identity platforms that process Aadhaar, biometric data, and personal records, the DPDP Act will significantly change how trust and compliance are managed.
What the DPDP Act Says—At a Glance
While we await formal implementation, here’s what the DPDP Act outlines:
- Consent-first: Personal data cannot be collected or processed without explicit user consent.
- Purpose limitation: Data must only be used for the reason it was collected.
- Data minimization: Platforms can only collect what is absolutely necessary.
- Right to correction and erasure: Individuals can request updates or deletion of their data.
- Accountability: Platforms are responsible for ensuring compliance—even when outsourcing processing.
Key Players in the DPDP Ecosystem
To understand compliance under the DPDP Act, it’s crucial to know who’s responsible for what. Here are the main actors the law defines:
| Actor | Who They Are |
| Data Principal | You—the individual whose personal data is being collected or processed. |
| Data Fiduciary | The entity (company, institution, platform) that determines why and how data is processed. |
| Data Processor | A third party that processes data on behalf of a Data Fiduciary, without making decisions about its use. |
| Consent Manager | A registered platform that helps Data Principals view, give, or withdraw consent across services. |
| Data Protection Board | The enforcement and adjudication body for grievances, breaches, and non-compliance under the Act. |
This ecosystem will become active once the law is enforced, meaning platforms and public institutions will need to clearly identify and document their role—especially when working with partners or vendors.
What It Means for Digital Identity Platforms
Digital identity platforms like Ooru Digital’s CredIssuer and BioChq operate at the intersection of sensitive data, authentication, and verification. Once enforced, the DPDP Act will require:
1. Explicit Consent in Every Flow
Credential issuance, biometric verification, or wallet integrations must show clear, affirmative user consent. No more implied or passive data collection.
2. Minimal and Contextual Data Usage
Only data necessary for identity verification or credential issuance should be collected. For example, issuing a student certificate shouldn’t expose unrelated personal data like address or parent names.
3. User Visibility and Control
Users will expect control over their credentials—how they’re stored, shared, or deleted. This will make verifiable credentials + wallets even more relevant, as they empower user-side data sharing.
4. Auditable and Tamper-Proof Logs
DPDP calls for accountability. This aligns naturally with digital credentials that are cryptographically signed and verifiable—a key strength of platforms like CredIssuer.
5. Processor and Fiduciary Boundaries
Platforms must clearly define their roles: Are you a Data Fiduciary or a Processor for a ministry, university, or bank? Each role carries different compliance responsibilities.
The Challenges Ahead (And Why Preparation Matters)
Many public and private systems still run on legacy or paper workflows. The shift to digital identity infrastructure is happening fast—but often without built-in compliance mechanisms.
When the DPDP Act is enforced:
- Non-compliance could mean penalties
- Government RFPs may require DPDP readiness
- Public trust will depend on data transparency
Now is the time for platforms to embed privacy-by-design, auditability, and selective disclosure protocols.
How Ooru Digital is Preparing for DPDP
Even before enforcement, Ooru Digital is aligning its products with the spirit of the law:
- Built-in Consent Layers across issuance and verification flows
- Data Minimization by Default, using selective field disclosure
- W3C-Compliant Credential Standards for global interoperability and user control
- Tamper-Proof Audit Trails for every issuance and verification
- Role-Based Access to ensure data doesn’t travel beyond its purpose
Conclusion: Future-Proofing Trust
While the DPDP Act is not yet in effect, its arrival is inevitable. For digital identity platforms, this isn’t just a legal checkpoint—it’s a chance to build more trustworthy, transparent, and user-first systems.
By preparing now, platforms can be the vanguard of ethical digital identity, not just compliant but competitive in a privacy-aware future.