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Data Principal Rights: What Your Users Can Now Demand

Data Principal Rights: What Your Users Can Now Demand

Access, correction, erasure, and nomination. DPDPA gives data principals significant rights. Here's how to build workflows that handle these requests efficiently.

DPDPA empowers Data Principals, the individuals whose data is being processed, with a clear set of rights. These include the right to access information about how their data is being processed, the right to correction and erasure of inaccurate or unnecessary data, the right to grievance redressal, and the right to nominate another person to exercise these rights on their behalf. Organisations must be prepared to handle these requests efficiently and within reasonable timeframes.

Right to Access

Data Principals can request a summary of the personal data being processed, the processing purposes, the categories of data involved, and details of any sharing with third parties. Your systems need to be able to compile this information quickly. Organisations that maintain well-structured data inventories can respond to access requests in hours rather than weeks.

Right to Correction and Erasure

Users can demand that inaccurate data be corrected and that data no longer necessary for its original purpose be erased. Implementing erasure is technically challenging when data has been replicated across backups, analytics systems, and third-party processors. Design your data architecture with deletion in mind: maintain clear data lineage, use soft-delete mechanisms that can cascade across systems, and have processes to verify that erasure has been completed across all copies.

Right to Nomination

A distinctive feature of DPDPA is the right of a Data Principal to nominate another individual to exercise their rights in case of death or incapacity. This requires building nomination management into your user account systems, including verification of the nominated person's identity and clear processes for when and how the nomination takes effect.

Operationalising Rights Requests

Build a centralised intake system for rights requests that logs the request, verifies the requester's identity, routes it to the appropriate team, tracks progress, and generates confirmation of completion. Automation can handle the majority of straightforward requests, with human review reserved for complex cases involving data shared across multiple systems or jurisdictions.