DPDP Compliance for Telecom Companies
Telecom operators are India's largest data processors by volume — call records, location data, brows
Discuss this page with an LLM
Now replace the sandwich shop with your Telecom company. Where does personal data enter? Where does it sit? Who else touches it?
Telecom DPDP Self-Check
Start here to understand why DPDP is relevant to Telecom. Before any other task, first understand how personal data moves through the business.
What is Telecom?
In this context, Telecom means the websites, apps, operations, support teams, customer records, employee systems, vendor tools and data workflows that collect or use personal data.
Children's data
- Do you collect age, class, school, parent details or learning progress?
- Can you separate child, parent and guardian data?
- Do you know which users are under 18?
Consent
- Can you prove where consent came from?
- Is consent collected before data is used for the stated purpose?
- Can consent be withdrawn without breaking the entire account flow?
Tracking and profiling
- Do you track usage, performance, attention, behavior or drop-offs?
- Is any of this used for ads, recommendations or nudges?
- Are analytics tools collecting user identifiers?
Vendors and SDKs
- Which CRMs, email tools, payment tools, analytics tools and support tools receive personal data?
- Do contracts say they process data only on your instructions?
- Can you delete or export data from each vendor?
Retention
- What happens when the service ends?
- What happens when a user leaves?
- What data is kept for certificates, invoices, disputes or regulatory records?
First action
- Map one user journey from sign-up to completion.
- Mark where data is collected, stored, shared, used for communication and deleted.
If this self-check exposed more than three unclear answers, the next useful step is a DPDP data journey map.
Book a DPDP clarity callTelecom Company Analyses
Airtel
Airtel's privacy policy, updated in June 2024, makes an effort towards transparency but doesn't fully align with the DPDP Act 2023. Key gaps include ambiguous data retention, lack of explicit cross-border transfer details, and broadly defined legitimate uses which could fall short of DPDP's specific consent requirements.
Reliance Jio
Reliance Jio's privacy policy, while comprehensive in listing data categories, falls short on explicit DPDP Act 2023 alignment. Key areas like granular consent, specific data retention, and DPDP-mandated grievance escalation need significant updates to mitigate regulatory risk for its vast user base.
Frequently asked questions
How do we handle DoT requirements to store logs if a customer requests data deletion?
Legal obligations from the Department of Telecommunications override a user's request for erasure. You must retain the specific logs required by law but must delete any auxiliary data used for marketing or customer profiling.
Does international roaming data shared with foreign carriers count as a cross-border transfer?
Yes, sharing subscriber data with a foreign telco to enable roaming is a transfer. You must ensure the destination country is not on the central government’s restricted list and that the data shared is limited to what is necessary for connectivity.
Are we responsible for how a third-party app uses the OTP we deliver?
You are responsible for the security of the delivery channel and the data used to route the SMS. However, once the user provides that OTP to a third-party app, that app becomes the data fiduciary for the subsequent transaction.