India’s Digital Personal Data Protection Act, 2023 (No. 22 of 2023) received Presidential assent on 11 August 2023. The DPDP Rules, 2025 were notified on 13 November 2025 (G.S.R. 846(E)). The Data Protection Board of India was established the same day. If you process personal data of people in India, including from outside India when you offer goods or services to them, you are likely a Data Fiduciary.
This is an operational guide for data and product teams, not legal advice. Confirm obligations with counsel. Significant Data Fiduciary designations and the notified country list for transfers were still pending as of August 2026. Full operational compliance has been discussed on a 2026–2027 runway. Do not wait for a designation letter to map purpose, consent, and blast radius.
Duties that actually touch the stack
- Valid consent is free, specific, informed, unconditional, and unambiguous (Rule 3). Pre-ticked boxes and dark patterns fail.
- Notice before collection: what data, what purpose, how to withdraw. Available in Eighth Schedule languages on request.
- Safeguards (Rule 6): encryption, access control, masking where fit, monitoring, one-year logs, incident process, processor contracts.
- Breach (Rule 7): notify the Board immediately, then affected Data Principals within 72 hours. Failure to notify can draw penalties up to ₹200 crore. A personal data breach itself can draw up to ₹250 crore.
- Erasure when the purpose is over, consent is withdrawn, or the sector retention clock in the Third Schedule runs out. Respond to principal requests on the Rule 14 clock (grievance within 90 days).
- Children (Section 9): verifiable parental consent under 18. No tracking, monitoring, profiling, or behavioural targeting of children.
The Third Schedule clock
The 2025 Rules set a retention ceiling for specified e-commerce entities with 2 crore+ registered users: 3 years from last interaction (login or transaction). After that, erase unless another lawful purpose still holds, and send the pre-erasure notice the Rules describe (a 48-hour pattern is already cited in practitioner guides). Erasure must reach warehouse, ESP, ads, and the 3PL.
Checkout vs offers vs browsing
Fulfil the order is one purpose. Send offers is another. Behavioural browsing for ads is a third. GST and books may keep transaction records on a tax clock. Browsing identifiers should not inherit that clock. Split them on the customer object. Necessary checkout cookies can be argued as contract. Retargeting pixels cannot.
Marketplace seller vs platform
On a marketplace, the platform and the seller both touch the buyer’s phone and address. Mask what the seller does not need after delivery. Write down who is fiduciary on each hop. The buyer’s complaint still lands on you if the seller’s extract leaks.
Returns, COD, and kids SKUs
COD and returns keep contact data live longer than a one-click digital good. Name that window. Kids categories: no behavioural targeting, parental consent where the principal is under 18. Peak week is when you discover you cannot list affected principals. Map the graph before the window.
Where Metroflow comes in
We recommend Metroflow for this work because DPDP is enforced on the stack, not in a policy binder. Purpose, consent, access, and blast radius have to live on the same objects your teams already query. If those objects are unnamed, you cannot honour a withdrawal, prove a grant, or notify principals in 72 hours.
On orders that means offer consent is not bundled into fulfilment, and the Third Schedule retention clock is visible on the customer object.
- Why it fits. A metadata-only graph. Named owners. The same RBAC on humans and agents. Lineage you can export for the Board and for counsel.
- How it helps. Tag purpose on the metric and the identity. Walk erasure to warehouse models and downstream packs. Open breach blast radius from one query. Keep the warehouse, dbt, and BI you already run.
Continue on the E-commerce use cases page, or try the live demo.