Data Principal Rights under DPDP Act – What Indian Businesses Get Wrong

TL;DR (for busy founders)

Under the DPDP Act, individuals (Data Principals) have enforceable rights over their personal data. Most compliance failures happen not because businesses deny these rights, but because they lack a clear internal process to receive, verify, respond to, and document requests.

Introduction

The Digital Personal Data Protection Act, 2023 (DPDP Act) gives individuals—referred to as Data Principals—specific rights over their personal data.

While many organisations acknowledge these rights in their privacy policies, far fewer are prepared to operationally handle them.

In practice, DPDP risk often begins with a simple email:

“Please tell me what data you have about me.”

This article explains:

  • What Data Principal rights actually mean under DPDP

  • Where businesses commonly go wrong

  • How Indian SMEs can handle rights requests without over-engineering compliance

Who Is a Data Principal under DPDP?

A Data Principal is the individual to whom personal data relates.

This includes:

  • Customers

  • Employees

  • Users

  • Vendors (where personal data is involved)

If your organisation processes personal data in digital form, it will inevitably receive Data Principal requests—formally or informally.

What Rights Does DPDP Provide to Data Principals?

While DPDP rights may evolve through rules and guidance, the core rights include:

1. Right to Access Information

Data Principals can request:

  • Confirmation of whether their personal data is being processed

  • Information about the nature and purpose of processing

2. Right to Correction

Individuals may request correction of:

  • Inaccurate data

  • Incomplete data

This requires businesses to have clear update mechanisms, not just disclaimers.

3. Right to Erasure (Where Applicable)

Data Principals may request deletion of personal data where:

  • The purpose has been fulfilled

  • Retention is no longer legally required

Erasure is not absolute, but must be assessed reasonably.

4. Right of Grievance Redressal

DPDP expects organisations to provide:

  • A clear grievance or contact mechanism

  • A way to respond meaningfully to concerns

Silence or delay creates exposure.

5. Right to Nominate

Data Principals can nominate another individual to exercise their rights in certain circumstances.

This is often overlooked in implementation.

What Businesses Commonly Get Wrong

1. No Defined Intake Channel

Many organisations:

  • Don’t specify where rights requests should be sent

  • Treat them as generic support emails

This leads to delays and missed obligations.

2. No Identity Verification Process

Responding without verification risks:

  • Disclosure to the wrong person

  • Secondary data breaches

Verification does not need to be complex—but it must exist.

3. No Timeline Awareness

DPDP imposes expectations around timely responses.

Without internal timelines:

  • Requests linger

  • Escalations increase

4. No Documentation of Actions Taken

Even when requests are handled correctly, many businesses:

  • Don’t record the request

  • Don’t document the response

Under DPDP, accountability matters.

5. Treating Rights Requests as One-Off Events

Rights handling should be:

  • Repeatable

  • Predictable

  • Process-driven

Ad-hoc handling increases inconsistency and risk.

What DPDP Actually Expects in Practice

DPDP does not require sophisticated rights management platforms for SMEs.

At a minimum, organisations should have:

  • One designated intake channel

  • A basic SOP for handling requests

  • A way to verify identity

  • A register to record requests and responses

  • Clear internal responsibility

This demonstrates preparedness, which carries significant weight.

A Practical SME-Friendly Approach

A defensible approach for most SMEs includes:

  1. A single email/contact point for rights requests

  2. A simple identity verification checklist

  3. A documented response workflow

  4. A basic register (spreadsheet works)

  5. Clear escalation for complex cases

This balances compliance with operational reality.

Why Rights Handling Is a High-Risk Area

Most regulatory complaints arise not from mass violations, but from:

  • One ignored email

  • One delayed response

  • One poorly handled request

Rights handling is where documentation meets human interaction—and mistakes become visible.

Closing Thought

Data Principal rights under DPDP are not theoretical.

They are practical, enforceable, and increasingly exercised.

For Indian SMEs, readiness is less about volume and more about having a calm, documented process in place before the first request arrives.

Related Resource

DPDP360™ includes a Data Principal Rights Handling SOP and a ready-to-use request register designed specifically for Indian SMEs.

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