The PDPA contained 112 sections divided into 15 chapters. The new version PDPA 2019 contains 98 sections and is structured as follows:
|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|
|IX||41-56||Data Protection authority of India|
|X||57-66||Penalties and Compensation|
|XII||78-81||Finance, Accounts and Audit|
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.