HRs Role in Navigating New Data Privacy Rules in India: Ensuring Employee Consent and Responding to - CiteHR

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On Nov 14, 2025, MeitY notified the Digital Personal Data Protection Rules, 2025, operationalising the DPDP Act, 2023. A government note on Nov 17 confirmed the Rules after nationwide consultations. For employers, this moves data privacy from policy talk to day-to-day payroll, HRIS, background checks, CCTV, BYOD, productivity tools, and vendor portals. Expect explicit duties on notices/consent, purpose limitation, retention schedules, grievance redress, children’s data protections, and fast breach reporting to the Data Protection Board—plus clearer accountability for data processors (payroll, insurtech, ATS, background-check partners). Separately, reports indicate the Centre may tighten compliance timelines after industry feedback, which would compress HR tech changeovers.
@PIB; @Bar&Bench; @ET

The emotional reality inside companies: most employees didn’t sign up to be “data subjects,” yet their most intimate details—health claims, family IDs, bank accounts, grievance notes, even keystroke logs—sit across multiple systems. Trust will hinge on whether leaders explain plainly what’s collected, why, for how long, and how to say no (or delete) without career risk. HRBPs and IT face anxiety over legacy spreadsheets, WhatsApp workflow leaks, and vendors who promise compliance but can’t prove it. Employees want dignity and control; managers want workable processes; auditors want evidence. If your privacy posture relies on hope, staff will feel watched—not protected.
Press Information Bureau
@PIB

Compliance/leadership lens: run an HR data map (fields, systems, processors), lock a retention schedule, and update collection notices at source (forms, portals, cameras). Bake privacy into policy + UI: separate consent from employment acceptance, default to least data, and make access/correction routes obvious. Execute vendor DPAs with security and sub-processor clauses; verify cross-border handling in your HR stack; and stage breach drills. Train line managers not to over-collect “just in case.” Publish a one-page staff explainer in English + local language. What you can’t document, you can’t defend.
@Bar&Bench

What is one employee data flow you’ll stop or simplify this week (e.g., medical notes on email, IDs on open spreadsheets)?

Which two vendor systems will you audit first for lawful basis, retention, and breach response?


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To address the first part of your question, one employee data flow that could be simplified is the process of handling medical notes. Instead of using email, which can be insecure, consider implementing a secure HR portal where employees can upload their medical notes directly. This not only enhances data security but also streamlines the process.

As for the second part of your question, the two vendor systems that should be audited first for lawful basis, retention, and breach response are the HRIS (Human Resource Information System) and the payroll system. These two systems typically hold the most sensitive employee data and are therefore the most critical to secure.

1. For the HRIS, ensure that it collects only the necessary data, retains it only for as long as necessary, and has robust breach response mechanisms in place.
2. For the payroll system, verify that it complies with all relevant tax laws and regulations, retains data for the required period, and has a strong breach response protocol.

Remember, the goal is to ensure that all systems handling employee data are compliant with the new Digital Personal Data Protection Rules, 2025.

From India, Gurugram
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