Aadhaar Data Under DPDP: What Changes?
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DPDP Action Sheet
Use this before your next workflow goes live. It keeps the useful parts visible and turns DPDP into checks your team can actually answer.
For Aadhaar Data Under DPDP: What Changes?, the DPDP question is how personal data enters the workflow, where it is stored, which tools touch it, what purpose was explained, and how deletion or withdrawal will work.
1. Lead Forms
Check:
- What data are you collecting?
- Is the purpose clear at the point of collection?
- Is marketing consent separate from service communication?
- Can the user withdraw consent later?
Common mistake: one checkbox that silently covers newsletters, sales calls, partner sharing and remarketing.
2. Email and WhatsApp
Check:
- Who is on the list?
- Where did consent come from?
- Is the list imported from a vendor, event, webinar, scrape or old CRM?
- Can you prove the source of consent?
Common mistake: treating every lead as permanently marketable.
3. Ads and Retargeting
Check:
- Are pixels or ad platforms receiving identifiable user behavior?
- Are audiences built from customer lists?
- Are lookalike or remarketing audiences using personal data?
Common mistake: assuming "the ad platform handles it" means your company has no DPDP responsibility.
4. Website Analytics
Check:
- Which tools run on the site?
- Are IP address, device identifiers, session IDs or form fields being captured?
- Is analytics used only for measurement, or also for profiling and targeting?
Common mistake: installing tools first and asking privacy questions later.
5. Vendor List
Make a quick list:
- CRM
- Email platform
- WhatsApp provider
- Analytics
- Ad pixels
- Form tool
- Landing page builder
- Webinar tool
For each vendor, answer: what data goes there, why, who can access it and how deletion works.
6. This Week's Action
Map one campaign from first click to final follow-up. Mark every place personal data is collected, enriched, shared, uploaded or used for targeting.
If your team cannot answer where the data came from and where it goes next, start with a data flow map before rewriting policy copy.
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The Conflict Between Retention and Deletion
The Aadhaar Act often requires keeping authentication logs for specific periods, while the DPDP Act mandates deleting data once its purpose is served. You must categorize your Aadhaar data into “Regulatory” (required by UIDAI) and “Business” (used for internal records). DPDP requires you to purge Aadhaar-linked demographic data from your marketing databases the moment a customer closes their account, even if you are legally forced to keep the authentication log elsewhere.
Masking and Purpose Limitation
Storing full 12-digit Aadhaar numbers in plain text for simple identity proofing violates DPDP’s data minimization principle. If you only need to verify an identity once, keeping a full digital color copy of the card on your server creates unnecessary risk. Non-regulated entities must transition to storing only masked Aadhaar copies where the first eight digits are hidden to comply with both UIDAI circulars and DPDP’s “reasonable security” standards.
| Workflow | Data Involved | DPDP Risk |
|---|---|---|
| eKYC Onboarding | Biometric/OTP logs | Over-collection of data beyond the verification event |
| Employee Payroll | Aadhaar-linked bank details | Unauthorized sharing with third-party insurance or benefit vendors |
| Visitor Management | Physical Aadhaar photocopies | Storing unmasked copies in unsecured physical registers |
| Contractor Verification | Demographic QR code data | Processing data for background checks without specific consent |
This week
Search your company’s shared drives and local “Downloads” folders for PDF copies of Aadhaar cards. Permanently delete any files where the verification is already complete, or use a redacting tool to mask the first eight digits of the Aadhaar number on stored digital documents.
Now think about your work. Where does personal data enter your workflows? Where does it sit? Who else touches it?
Frequently asked questions
Can I keep a physical photocopy of a customer's Aadhaar card?
You may only keep it if the first eight digits are blacked out. DPDP requires data minimization, so storing the full 12-digit number for a routine business transaction is considered excessive.
Does DPDP override the Aadhaar Act's record-keeping rules?
No, specific laws like the Aadhaar Act take precedence for retention. However, you cannot use that retained data for any secondary purpose, such as credit profiling or marketing, without a separate DPDP-compliant consent notice.
Must I delete Aadhaar data if a user withdraws consent?
You must stop all processing immediately and delete the data unless a separate Indian law requires you to keep it for audit or tax purposes. You must provide the user with the specific legal reason why the data cannot be deleted yet.