How the structure of PDPA 2019 has changed

The PDPA contained 112 sections divided into 15 chapters. The new version PDPA 2019 contains 98 sections and is structured as follows:

Chapter Sections Title
I 1-3 Preliminary
II 4-11 Obligations of Data Fiduciary
III 12-15 Grounds for processing personal data without consent
IV 16 Personal data and sensitive personal data of children
V 17-21 Rights of Data Principal
VI 22-32 Transparency and Accountability measures
VII 33-34 Restriction on transfer of personal data outside India
VIII 35-40 Exemptions
IX 41-56 Data Protection authority of India
X 57-66 Penalties and Compensation
XI 66-77 Appellate Tribunal
XII 78-81 Finance, Accounts and Audit
XIII 82-85 Offences
XIV 86-98 Miscellaneous

It is important to note that the chapter on “Transition” that set a time line for implementation is no longer there. This could mean that the Act may be effective as soon as it is passed into law though DPA may not be in place.

The Grounds of processing which were contained in three chapters earlier has now been condensed into one chapter.


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