Glossary · Privacy and data protection
The data principal is the person at the centre of every DPDP obligation.
The individual whom personal data is about under India's DPDP Act, including a parent or lawful guardian acting for a child or for a person with a disability.
Back to the glossary01 · In plain words
In plain words
The individual whom personal data is about under India's DPDP Act, including a parent or lawful guardian acting for a child or for a person with a disability.
If the data describes you, you are its data principal. The DPDP Act gives that person rights over the data and a few duties of their own. For a child under eighteen, the parent or lawful guardian is treated as part of the principal, and the same goes for a lawful guardian acting for a person with a disability.
02 · Why it matters
Why it matters
Who cares about this, and what depends on it.
Every right in the Act belongs to the data principal: to get a summary of what is processed and who it was shared with, to correct, complete, update or erase it, to use a grievance process, and to nominate someone to act if they die or cannot act. The DPDP Rules, 2025 ask fiduciaries to publish how to make a request and to answer grievances within a period they publish, which cannot exceed ninety days. Unusually, the Act also gives principals duties: not to impersonate others, not to file false or frivolous complaints, and to give authentic information when asking for a correction. Breaching those duties carries a ceiling of ten thousand rupees.
03 · Where you meet it
Where you will meet it
The documents, meetings and reports where it appears.
- The rights request page
- The page or in-app form where people ask for access, correction or erasure, with the identifier you need to find their records.
- A grievance ticket
- Each complaint from a principal, the response and the date, kept as evidence that the published window was met.
- Sign-up and consent screens
- Where you decide whether the user is a child, and so whether a parent must give verifiable consent.
- A complaint before the Board
- A principal must normally use your grievance process first before going to the Data Protection Board of India.
04 · An example
A worked example
An illustration, not a real client.
Illustrative: a coaching institute and a seventeen-year-old student
A test-prep institute enrols a student aged seventeen through its app. Because the student is a child under the Act, the data principal includes her parent, and the institute needs the parent's verifiable consent before processing. When she turns eighteen and asks the institute to correct her school name, she makes that request herself. The institute checks the identifier it asked for at sign-up, fixes the record, and logs the date.
05 · Easy to mix up
Easy to mix up with
Neighbouring terms that mean something different.
- Data subject
- The GDPR's term for the person the data relates to. The DPDP Act adds guardians into the definition and gives the person duties too.
- Consent manager
- A registered platform a principal can use to give, review and withdraw consent. It acts for the principal but is not the principal.
06 · What to do
What to do with it
Practical steps, and the guides that go deeper.
- Publish one clear route for rights requests and say what identifier you need.
- Publish your grievance response period and make sure it stays within ninety days.
- Decide how you will spot a child at sign-up and how you will verify the parent.
- Record nominations so a nominee can act when the principal cannot.
- GuideData principal rights, and running requestsThe rights people hold, and a workflow that answers them.
- GuideChildren's data and parental consentVerifiable consent, the limits on tracking, and the exemptions.
- GuideValid consent and noticesWhat a notice says and what makes consent count.
Sources: Digital Personal Data Protection Act, 2023, sections 2, 9, 11 to 15 and the Schedule; Digital Personal Data Protection Rules, 2025, rules 10 and 14. Not legal advice.
Questions about Data principal
Is an employee a data principal?
Yes, for the personal data the employer holds about them.
An employee is an individual the data relates to, so they are a data principal. Much employment processing can rely on the Act's legitimate uses rather than consent, but the employee's rights, such as correction and grievance, still apply.
Can a principal be penalised?
Yes, for breaching their own duties, with a low ceiling.
The Schedule sets a ceiling of ten thousand rupees for a principal who breaches the duties in section 15, such as filing a frivolous complaint or impersonating someone. The Board decides whether a penalty applies.
Related guides
- Data fiduciaryThe person or organisation that decides, alone or with others, why and how personal data is processed, and so answers for it under India's DPDP Act.
- Consent managerUnder the DPDP Act, a person registered with the Data Protection Board who gives individuals one interoperable platform to give, manage, review and withdraw consent.
- DPDP ActIndia's law on processing digital personal data, passed in August 2023 and switched on in stages by the 2025 Rules made under it.
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