RESPONSE TO THE PUBLIC CONSULTATION DRIVE BY MINISTRY OF ELECTRONICS AND INFORMATION TECHNOLOGY: DRAFT DIGITAL PERSONAL DATA PROTECTION RULES, 2025

Centre for Advanced Studies in Cyber Law and Artificial Intelligence (CASCA), with insights from our Faculty Coordinator Dr. Ivneet Walia, has submitted its response to the Ministry of Electronics and Information Technology's public consultation on the Draft Digital Personal Data Protection Rules, 2025. The response makes several recommendations for strengthening the rules and making them more effective in protecting personal data. Some of the key recommendations include:

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1. Expanding the definition of Data Fiduciary to include Guardian Data Fiduciaries, who are responsible for processing large amounts of children's data.

 

2. Mandating a 60-day procedural review period for Consent Manager applications.

 

3. Requiring Data Fiduciaries to notify Data Principals of a data breach within 24 hours of its occurrence.

 

4. Removing the "net worth" criterion for becoming a Consent Manager.

 

5. Defining and implementing the "exemption safeguard mechanism."

 

We believe that these recommendations will help to improve the Draft Digital Personal Data Protection Rules, 2025 and make them more effective in protecting personal data.