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DPDP Act 2023

Legal Intermediate

What is the DPDP Act?

The Digital Personal Data Protection Act (DPDP Act) 2023 is India’s comprehensive data protection legislation, modeled after the EU’s GDPR. It governs how personal data can be collected, processed, stored, and shared by organizations operating in India or dealing with Indian citizens’ data.

The DPDP Act 2023 is India’s answer to GDPR. What web scrapers need to know about India’s new data privacy law. If you’re collecting data from Indian users or businesses, this law affects you — big time.

Key Provisions for Data Scrapers

Provision Requirement Impact on Scraping
Consent Explicit consent for data collection Must have valid legal basis
Purpose Limitation Use data only for stated purpose Define scraping purpose clearly
Data Minimization Collect only what’s necessary Don’t scrape unnecessary personal data
Storage Limitation Delete when no longer needed Implement data retention policies
Cross-Border Transfer Some restrictions on data export Check data storage locations
Data Fiduciary Party collecting data has obligations You may be a fiduciary

What Counts as “Personal Data”?

Under DPDP Act, personal data includes:
├── Direct identifiers: Name, email, phone, Aadhaar
├── Indirect identifiers: IP address, device ID
├── Pseudonymous data: Cookie IDs, session tokens
└── Sensitive personal data: Financial, health, biometrics

Compliance Checklist for Scrapers

1. ✅ Identify if you're collecting personal data
2. ✅ Establish lawful basis (consent or legitimate interest)
3. ✅ Provide notice to data principals
4. ✅ Implement data retention policies
5. ✅ Allow data subjects to exercise rights
6. ✅ Ensure cross-border data transfer compliance
7. ✅ Maintain records of processing activities
8. ✅ Designate Data Protection Officer if required

Risk Assessment Framework

Risk Level Data Type Example Mitigation
Low Public business data Company addresses, public prices Minimal compliance needed
Medium Public personal data LinkedIn profiles, professional info Review terms of service
High Private personal data Phone numbers, residential addresses Requires explicit consent
Very High Sensitive personal data Health, financial, biometric Additional safeguards required

Common Scraping Scenarios

# LOW RISK: Public business data
scrapable = [
    "Company names and addresses",
    "Public pricing information",
    "Product catalogs",
    "Press releases"
]

# HIGH RISK: Personal data (needs consent)
restricted = [
    "Email addresses from websites",
    "Phone numbers",
    "Social media private profiles",
    "Financial records"
]

Legal tip: Always check a website’s robots.txt and Terms of Service before scraping. Violating ToS plus collecting personal data without consent = regulatory risk. When in doubt, consult a data protection attorney before scaling your scraping operations.

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