The DPDP Act · Glossary

Every DPDP term, defined in plain English.

India's Digital Personal Data Protection Act 2023 introduces a precise vocabulary — and misunderstanding a defined term is how compliance failures start. 50+ terms from the Act, the DPDP Rules 2025, and the technology that operationalises them, with section references where the law defines the word.

A – C

Aadhaar to Cross-Border.

Aadhaar-Based Verification

Identity verification using India's Aadhaar system (issued by UIDAI), via OTP to the registered mobile number or biometric authentication. Referenced in DPDP Rules 2025 Rule 6 as a mechanism for verifiable parental consent and in Rule 10(3) for identity verification before fulfilling rights requests.

Affirmative Action

The manner in which valid consent must be given under the DPDP Act — a positive, deliberate act by the Data Principal. Pre-ticked boxes, inferred consent from continued use, and silence do not constitute affirmative action. See Section 6(1).

Algorithmic Assessment

A requirement for Significant Data Fiduciaries under DPDP Rules 2025 Rule 7(2)(d) to periodically assess algorithms used in profiling or automated decision-making for accuracy, fairness, and bias. No methodology is prescribed — SDFs must design their own framework.

Append-Only Audit Trail

An audit log where records can only be inserted — never modified or deleted. TATA Tele Vishwaas AI uses this for the consent ledger and system-wide audit log, enforced at the database permission level, so records stay tamper-evident.

Breach Notification

The obligation under DPDP Act Section 8(6) and DPDP Rules 2025 for Data Fiduciaries to notify the Data Protection Board of India within 72 hours of becoming aware of a personal data breach, and affected Data Principals "as soon as reasonably practicable". CERT-In directions separately require a first notification within 6 hours for qualifying incidents.

Chain Hash

The cryptographic value linking each consent record to the one before it: SHA-256(record_hash + previous_chain_hash). Modifying any record invalidates the chain hash of every subsequent record. See also Hash Chain, Record Hash.

Children's Data

Personal data of individuals under 18. DPDP Act Section 9 and Rule 6 impose heightened obligations: verifiable parental consent, prohibition on tracking and targeted advertising directed at children, and age-verification expectations.

Compliance Gap Engine

A continuously running rules engine — event-driven plus a nightly scan — that checks an organisation's processing register against DPDP Sections 5, 6, 7, 8(2), 8(7), and 16. TATA Tele Vishwaas AI's engine monitors 15 gap types with 15 registered detectors; the compliance score is computed as 100 − (12 × critical + 6 × high + 3 × medium + 1 × low) over open and acknowledged gaps, and a two-scan safety guard stops a single transient scan error from silently mass-closing real gaps.

Cross-Border Data Transfer

Transfer of personal data outside India. DPDP Act Section 16 lets the Central Government restrict transfers to notified countries — no restriction notifications have been issued yet, but the framework exists. TATA Tele Vishwaas AI's Data Flow Map renders these transfers as a distinct lane and marks any transfer lacking a documented safeguard with a red dashed edge.

D

Dark Patterns to DPO.

Dark Patterns

UX patterns that manipulate users into actions they might not otherwise take: pre-ticked boxes, prominent "accept all" with buried "manage preferences", confusing double negatives, withdrawal made harder than consent. Dark patterns undermine the "free" and "unambiguous" requirements of valid DPDP consent.

Data Fiduciary

Under DPDP Act Section 2(i), any person who alone or with others determines the purpose and means of processing personal data. If your organisation decides why and how personal data is processed, you are a Data Fiduciary — and "fiduciary" signals the Act expects you to act in trust.

Data Principal

Under DPDP Act Section 2(j), the individual the personal data relates to. Children and persons of unsound mind are Data Principals too — consent is given by their parents, guardians, or legal representatives. Replaces GDPR's "data subject".

Data Processing Agreement (DPA)

The contract between a Data Fiduciary and a Data Processor governing how the processor handles personal data — purpose and scope, security obligations, sub-processing, breach notification, erasure on termination, audit rights.

Data Processor

Under DPDP Act Section 2(k), an entity processing personal data on behalf of a Data Fiduciary — cloud hosts, email platforms, CRM vendors, analytics providers. Processors act only on the fiduciary's instructions.

Data Discovery

A PII-discovery engine that connects to real data stores — object storage, file shares, and databases across AWS, Azure and Google Cloud, plus on-prem systems — samples content in memory, runs India-first detectors with checksum validation (Aadhaar/Verhoeff, PAN, GSTIN, payment card/Luhn, UPI and more), and discards the raw sample immediately, storing only a fingerprint and location. In TATA Tele Vishwaas AI every finding is a proposal reviewed by a DPO before anything downstream acts on it.

Data Protection Board of India (DPBI)

The regulatory body established under DPDP Act Chapter V. Adjudicates complaints, investigates breaches and non-compliance, issues binding orders, and imposes penalties of up to ₹250 crore per instance.

Data Protection Impact Assessment (DPIA)

A structured risk assessment of a processing activity — risks, likelihood, severity, mitigations. Mandatory for Significant Data Fiduciaries under Rule 7(2)(a); best practice for any high-risk processing.

Data Protection Officer (DPO)

The individual overseeing a Data Fiduciary's privacy programme. Mandatory for SDFs under Section 10(2)(a); must be based in India; serves as the contact point for the DPBI; reports to the board.

Data Residency

Storing and processing personal data within a specific territory. For Indian personal data, in-country hosting (e.g. AWS Mumbai, ap-south-1) is rapidly becoming a customer requirement even where the Act does not yet mandate it.

Dead-Letter Queue

In consent propagation, the queue holding webhook deliveries that failed after all retries. A dead-letter entry means a consent decision has not reached a downstream system — a gap requiring manual resolution, and exactly the kind of failure that must never be silent.

Digital Signature

A cryptographic binding of a signer to a record. In TATA Tele Vishwaas AI, each consent record is signed with the tenant's RSA-2048 private key held in a dedicated key-management layer — proving the record's origin and that it hasn't changed since signing.

DigiLocker

MeitY's digital document wallet, linked to Aadhaar. Referenced in DPDP Rules 2025 as a mechanism for verifiable age and identity verification.

DPO Gate

In TATA Tele Vishwaas AI's Data Discovery, the principle that every scan finding is a proposal, never a fact, until a human DPO reviews it — approve, reject, override, or accept-risk (DPO-only, justified, auto-returns for re-review). Nothing downstream acts on a finding before it clears this gate.

E – L

Eighth Schedule to Legitimate Use.

Eighth Schedule Languages

The 22 languages in the Eighth Schedule to the Constitution: Assamese, Bengali, Bodo, Dogri, Gujarati, Hindi, Kannada, Kashmiri, Konkani, Maithili, Malayalam, Manipuri, Marathi, Nepali, Odia, Punjabi, Sanskrit, Santali, Sindhi, Tamil, Telugu, Urdu. Rule 3 requires notices in English and available in these languages — TATA Tele Vishwaas AI supports all 22 plus English end to end.

Erasure Job

The systematic deletion of a Data Principal's personal data from every system holding it, required under Section 8(7) when consent is withdrawn or data is no longer necessary. TATA Tele Vishwaas AI's "Discovered" tab on the principal profile flags PII found in unregistered systems that a declared-inventory-only erasure would miss.

Field-Level Encryption

Encryption applied to individual database columns rather than whole disks. PII fields are encrypted with AES-256-GCM under keys managed in a dedicated key-management service — a database dump alone exposes no readable personal data.

Genesis Hash

The starting point of a tenant's hash chain — computed from a fixed genesis string plus the tenant's identity, binding the chain to that specific tenant and preventing chain transplantation.

Grievance Officer

Designated under the DPDP Rules to receive and redress Data Principal grievances; name and contact details published on the website and in the privacy notice. Grievances must be resolved within 30 days.

Grievance Redressal

The Section 13 right to complain about privacy violations or unresolved rights requests. Grievances must be resolved within 30 days; unresolved ones escalate to the DPBI — and every other rights-request type can also escalate once its own SLA lapses.

Hash Chain

A sequence of cryptographically linked records where each carries a hash of itself plus a reference to the previous record's hash — making the entire sequence tamper-evident. The foundation of TATA Tele Vishwaas AI's consent ledger.

HMAC (Hash-based Message Authentication Code)

A message-authentication code combining a hash function with a secret key. TATA Tele Vishwaas AI signs every consent-propagation webhook with HMAC-SHA256 so downstream systems can verify authenticity and integrity.

Identity Resolution

Determining that records across different systems refer to the same person. TATA Tele Vishwaas AI combines deterministic matching (exact email/phone) with probabilistic matching (name similarity + demographic signals), always operator-reviewed — critical for accurate rights fulfilment and complete erasure. Distinct from login disambiguation, which confirms which of two people sharing a phone or email is actually signing in.

Lawful Basis

The legal ground for processing. The DPDP Act recognises exactly two: consent (Section 6) and legitimate use (Section 7). There is no GDPR-style open-ended "legitimate interests" balancing test.

Legitimate Use

Section 7's specific, limited no-consent grounds: state functions, legal obligations, medical emergencies, employment-related processing, and other enumerated sub-grounds — eight canonical sub-grounds in all, each with its own conditions.

M – R

Minor to Row-Level Security.

Minor

An individual under 18 — the DPDP Act sets the age of digital consent at 18, higher than GDPR's default 16. Processing a minor's data requires verifiable parental consent. See Children's Data.

Non-Repudiation

The property that makes a record's origin undeniable. A non-repudiable consent record combines four mechanisms: SHA-256 hash chain (integrity), RSA digital signature (origin), RFC 3161 timestamp (independent time anchor), and append-only storage (mutation prevention) — tamper-evident and independently verifiable.

Notice

The Section 5 document a fiduciary must provide before or at collection: what data, why, how to exercise rights, how to complain, how to withdraw. Must be a standalone document (Rule 3) in English and available in the Eighth Schedule languages.

Notice Version

A specific published iteration of a privacy notice. Each consent record stores the content hash of the exact notice version active when consent was given — later edits to the notice can never retroactively change what a person agreed to.

Personal Data

Section 2(t): "any data about an individual who is identifiable by or in relation to such data" — deliberately broad, covering identifiers, behavioural, financial, health, and government-ID data. Only digital personal data is covered; pure paper records are out of scope.

Personal Data Breach

Section 2(u): any unauthorised processing, accidental disclosure, acquisition, sharing, use, alteration, destruction, or loss of access to personal data. Unlike GDPR there is no explicit high-risk threshold — the notification obligation reads as covering all breaches.

Purpose Limitation

Data collected for one purpose may not be processed for an incompatible other purpose without new consent. Under Section 8, fiduciaries process only for the specified, consented purpose.

Record Hash

The SHA-256 hash of a single consent record's canonical content (principal, purpose, action, text snapshot, timestamp — deterministically ordered). Input to both the chain hash and the digital signature.

RFC 3161

The IETF standard for Trusted Timestamp Authorities. A compliant TSA issues a cryptographically signed token proving a piece of data existed at a specific time. TATA Tele Vishwaas AI attaches an RFC 3161 timestamp token to every consent record — on by default for new tenants — making records tamper-evident and independently verifiable.

Row-Level Security (RLS)

A PostgreSQL feature restricting which rows a session can see based on its security context. TATA Tele Vishwaas AI applies RLS to its most sensitive tables as part of defence-in-depth tenant isolation, alongside query-level scoping enforced in the service layer.

RSA-2048

The public-key algorithm (2048-bit keys, considered secure through at least 2030) used to sign consent records — per-tenant private keys held in a dedicated key-management layer, never in the application database.

S – W

SDF to Withdrawal.

Significant Data Fiduciary (SDF)

A fiduciary designated under Section 10 based on data volume, sensitivity, and risk factors. SDFs must appoint an India-based DPO and an independent auditor, conduct DPIAs, and assess their algorithms.

SLA (Service Level Agreement)

The DPDP response clocks for rights requests: 90 days for access, correction, erasure, and nomination; 30 days for grievances. Missing an SLA gives the Data Principal grounds to escalate to the DPBI — for any request type; grievances additionally open an early escalation window the moment the organisation formally responds.

Standalone Notice

A privacy notice that exists as its own document — not buried inside Terms & Conditions or an EULA. Required by DPDP Rules 2025 Rule 3.

Timestamp Authority (TSA)

An entity issuing cryptographically signed RFC 3161 timestamps — independently verifiable proof of when a record existed, with clock and keys outside the Data Fiduciary's control.

TLS 1.3

The current standard for encrypting data in transit. External endpoints of DPDP-relevant systems should enforce modern TLS; versions 1.0 and 1.1 are deprecated and insecure.

Unified Principal Profile

The canonical record aggregating one person's identity across source systems (CRM, e-commerce, HRIS). Shows every system holding their data — the precondition for accurate Section 11 access responses and complete erasure orchestration.

UUID v7

A time-ordered universally-unique identifier format. TATA Tele Vishwaas AI uses UUID v7 primary keys so records order by creation time without a separate index — useful in an append-only ledger.

TATA Tele Vishwaas AI

विश्वास AI — India's Privacy & Consent Management Platform, a DrishVera Private Limited product sold through Tata Tele Business Services (TTBS). Cryptographically verifiable consent records, all 22 Eighth Schedule languages plus English, Data Principal rights management, breach management under the dual DPBI/CERT-In clocks, consent propagation, identity resolution, a RoPA module with a 15-detector compliance gap engine, and Data Discovery across AWS, Azure and Google Cloud. See vishwaas.ai.

Webhook

The HTTP callback mechanism delivering real-time consent decisions downstream. Every delivery is HMAC-SHA256 signed; attempts and outcomes are logged in the propagation delivery log.

Coming from GDPR?

The terminology mapping.

GDPR termDPDP Act equivalentKey difference
Data SubjectData PrincipalSame meaning
ControllerData Fiduciary"Fiduciary" signals a trust obligation
ProcessorData ProcessorEquivalent
Supervisory AuthorityData Protection Board of India (DPBI)One national body vs 27 EU DPAs
Legitimate Interests(no equivalent)Section 7 grounds are specific and narrower
Data Portability(not granted by the Act)
Right to Object(not granted by the Act)
Data Subject RightsData Principal Rights90-day SLA (30 days for grievances) vs GDPR's one month

Fluent in the vocabulary. Now operationalise it.

Every defined term above maps to a workflow in TATA Tele Vishwaas AI — consent, notices, rights, breach, RoPA, and discovery, with evidence a regulator can verify.