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- Erasure when the purpose is over, consent is withdrawn, or the sector retention clock in the Third Schedule runs out.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.
Medical emergency is not “export everything”
Section 7(f) and 7(g) recognise medical emergencies and public health. They exist so an ER can treat an unconscious patient without a checkbox. They do not let a research extract, a vendor LLM, or a quality warehouse copy every identifier “just in case.” When the emergency ends, the purpose ends. Children’s data still needs verifiable parental consent outside that window.
Tiered consent, not one form
Treatment, claims, quality measurement, and research are different purposes. A patient can agree to care and refuse a research registry. Put those flags on the member object. Quality measures should cut from encounter grain without dragging research identifiers into a vendor cloud.
Telemedicine and the same standard
A video consult is still an encounter. Recordings, chat transcripts, and e-prescriptions are personal data. The same grant that applies on the ward applies on the app. Do not drop a third-party transcription vendor into the call without a processor contract and a purpose.
Claims and ABDM-adjacent flows
Payor extracts and health-ID rails multiply processors. Name who is fiduciary vs processor on each hop. Breach notice has to include which partner still held the slice. On-prem or VPC when catalogs cannot leave the perimeter.
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 care and claims that means minimum necessary is the same grant on chat, quality tiles, and extracts. PHI tags travel with the asset.
- 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 Healthcare use cases page, or try the live demo.