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- Erasure when the purpose is over, consent is withdrawn, or the sector retention clock in the Third Schedule runs out.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.
Why platform owns half of DPDP
Rule 6 is encryption, access control, monitoring, one-year logs, incident process, and processor contracts. Those live in the warehouse, the orchestrator, and the agent runtime. A privacy PDF cannot answer “who queried email last quarter.”
Agents are a processing surface
Company Brain, copilots, and ticket bots retrieve columns. If the assistant can see a field the role cannot, you do not have a control. You have a demo. Agents inherit the same grant as the human. Retrieval logs count toward the one-year Rule 6 log duty. Prompt caches and embedding stores are processors if a vendor holds them.
Crawlers, vendors, and sub-processors
A Data Fiduciary may engage a processor only under a valid contract. Metroflow crawlers, the warehouse vendor, the LLM host, and the on-call pager vendor all sit on that list. No new sub-processor without authorisation. List crawlers in the VPC audit. Breach notice has to include which vendor still held the slice.
Shadow extracts
The DPDP miss is often a CSV on a laptop, a personal Looker explore, or a “temp” S3 dump from last QBR. If it is not in the inventory, it is not in the brain, and it will not be in the 72-hour list. Unused extracts should have a named sunset. That is hygiene and it is a safeguard.
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 the platform that means a column tagged personal data cannot reach an agent the role cannot see, and the 72-hour notice starts from a lineage query.
- 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 IT & Data use cases page, or try the live demo.