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DPDP Act guide

Rights of Data Principals under the DPDP Act

The DPDP Act calls the person whose data you hold a Data Principal and gives them a short, specific list of rights. Knowing exactly what is on that list, and what is not, keeps request handling focused on the duties that actually apply.

The law as of October 2026.

In shortAs of October 2026

  1. The rights are access, correction, completion, updating, erasure, grievance redressal and nomination.
  2. Portability is not a DPDP right.
  3. Most of the effort sits behind the request form: finding data across systems and proving the action.
  4. Legal retention duties can override erasure, so record the reason when you keep data.

The rights, in plain words

A Data Principal can ask you for information about their personal data, ask you to fix it, ask you to erase it, complain to you when something goes wrong, and name someone to act for them if they die or cannot act. That is the whole list.

  • Access to information: a summary of the personal data you process about them and what you do with it, and the other Data Fiduciaries and processors you have shared it with
  • Correction, completion and updating of inaccurate, incomplete or out of date data
  • Erasure of data you no longer need, unless you must keep it to meet a legal obligation
  • Grievance redressal: a way to raise a complaint with you, which you must answer
  • Nomination: naming another person to exercise these rights on their behalf in the event of death or incapacity

What is not a DPDP right

There is no right to data portability in the DPDP Act. If a customer asks to have their data moved to a competitor in a machine readable format, that request may arise under a sector rule or a contract; this Act does not create it. Do not promise it as a DPDP right in your notices or your Privacy Centre.

Data Principals also have duties under the Act, such as not filing false or frivolous complaints. Breaching those duties can attract a penalty of up to 10,000 rupees.

Where requests get stuck

Take a hospital. A patient asks for erasure of her records from the appointment app. The app team deletes the profile, but copies sit in the lab system, the billing software, a WhatsApp chatbot vendor and last month's backup. Some of those, such as clinical records, the hospital may have to keep under other laws. Someone has to decide, system by system, what is erased, what is kept and why, and then show the decision.

The difficult work sits behind the form on the website: identifying the person, finding their data across systems, applying the right exception, acting, confirming and replying.

Before the right reaches the requester

Rights only work if people know how to use them. Your notice must tell Data Principals how to exercise their rights and how to complain to the Board. The Rules also expect you to publish how a request can be made and the details the person needs to give.

Verify identity in a way that fits the risk. A request to update a delivery address needs less checking than a request for a copy of someone's loan history.

How TrustOS supports the work

The Privacy Centre gives Data Principals one place to make requests, raise grievances, nominate someone and track status. Each request then becomes an assigned task in the TrustOS workspace with an owner, a due date and a record of what was done.

Where systems are connected, connectors can search for the person's records, act on them and confirm the action, so your reply rests on evidence from the systems themselves. Which exceptions apply in your sector is a question for your legal team; TrustOS records the decision your legal team reaches and does not replace legal advice.

Free toolRequest deadline plannerEnter a request date and type, and see your targets and the 90 day grievance limit.

Official sources

This guide explains the law in plain words as of October 2026. It is not legal advice. Dates that depend on notifications can change, so check the official text before you rely on them.

Erasure, everywhere it lives

One request out, a confirmation back from each system

The erasure plan comes from the data inventory. Connectors act where they can, processors confirm, people close manual tasks, and anything kept under a legal duty is recorded with its reason.

ERASURE REQUESTREQ-2026-0418Ritika ShahIdentity checkedReceived 10 Oct · due 14 OctErasureplanfrom the data inventoryLoan appConnector · erasedCRMConnector · erasedData warehouseConnector · erasedEmail platformProcessor · confirmedCall recordingsTask · IT ops, doneKYC archiveKept · legal duty to retain5 erased, 1 kept with its reason · reply sent to Ritika · request closed

Questions

Common questions

Must we erase everything when a customer asks?

No. You erase data you no longer need for the specified purpose, unless keeping it is necessary to comply with a law. An NBFC may need to keep loan records under RBI requirements even after a customer asks for erasure. Record which data you kept and the legal reason.

Who can make a request for a child?

For a child, a parent or lawful guardian acts on the child's behalf. A nominee can act for a Data Principal who has died or cannot act, if one was nominated.

What happens if we do not resolve a grievance?

The Data Principal must first use your grievance process. If they are not satisfied, they can complain to the Data Protection Board once it is constituted and the relevant provisions apply.

Does the Act give a right to port data to another provider?

No. The DPDP Act does not include a data portability right.

See it with your data

Show us where your personal data lives. We will show you TrustOS running on it.

A 30 minute walkthrough on Google Meet with someone who knows the Act and the product. You leave with a view of your first phase, the owners and the effort.

Or get a rollout proposal in two minutes
  1. Step 1A 30 minute demo on Google MeetWith someone who knows the Act and the product.
  2. Step 2Your systems and purposesWe walk one product's personal data through TrustOS.
  3. Step 3A first phase you can planModules, owners and effort, written down for you to keep.