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Indian DPDP Act 2023 & DPDP Rules 2025: How Non-profits Need to Be Ready?

Protecting Personal Data, Building Trust and Strengthening India's Social Impact Ecosystem

Introduction

In today's digital world, non-profit organisations are increasingly using technology to connect with donors, register volunteers, identify beneficiaries, conduct fundraising campaigns, manage CSR partnerships and deliver social welfare programmes.

Behind every donation, volunteer registration or beneficiary record is personal information that deserves protection.

A donor shares their name, mobile number, email address and payment details. A volunteer provides contact information, skills and availability. A beneficiary may share sensitive details about their financial circumstances, family, education or health. NGOs also maintain information about employees, trustees, corporate partners and supporters.

How responsibly this information is collected, stored, processed and shared is becoming an important measure of organisational credibility.

India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the Digital Personal Data Protection Rules, 2025 (DPDP Rules) establish a new framework for protecting digital personal data. These regulations are not just relevant to large technology companies, banks and e-commerce platforms. They also have important implications for NGOs, charitable trusts, foundations and digital fundraising platforms.

For non-profits, data protection should be viewed not merely as a legal obligation but as an extension of their commitment to transparency, accountability and public trust.

1. Understanding India's DPDP Act 2023

The Digital Personal Data Protection Act, 2023, was enacted on 11 August 2023. The Government subsequently notified the DPDP Rules, 2025, on 14 November 2025, providing operational details and a phased implementation timeline.

The legislation seeks to balance two important objectives:

Protecting individuals' rights over their personal digital data.
Enabling organisations to process personal data for lawful purposes.

The Act applies to digital personal data processed within India, including personal data collected offline and subsequently digitised. It can also apply to processing outside India when connected with offering goods or services to individuals in India.

In the context of non-profits, this means that donor databases, online donation forms, volunteer registration systems, beneficiary management applications, email subscriptions and digital fundraising platforms may all fall within its scope.

An important point: An organisation does not need to be a commercial business to have data protection responsibilities. A charitable purpose does not automatically exempt an NGO from the DPDP framework.

2. Why Should NGOs and Non-profits Be Concerned?

Non-profit organisations routinely collect and process personal information from different stakeholders.

Consider the following examples:

Stakeholder	Personal data commonly collected
Donors	Name, mobile number, email, donation history and transaction references
Volunteers	Contact details, skills, location and participation records
Beneficiaries	Family details, income, education and programme-related information
Employees	Identity, employment, payroll and bank details
CSR partners	Representative names, business contact details and communications
Trustees and members	Contact details, identification and organisational records

Such information may be stored in spreadsheets, cloud applications, CRM systems, email platforms, websites, payment gateways and mobile applications.

If this information is accessed without authorisation, disclosed to third parties without proper authority, or retained longer than necessary, it can expose individuals and organisations to significant risks.

For an NGO, a data breach could result in:

Loss of donor confidence and credibility.
Misuse of beneficiaries' personal information.
Unauthorised fundraising communications.
Identity theft, phishing and financial fraud.
Reputational damage and legal consequences.

Organisations working with vulnerable communities, children, women, senior citizens and economically disadvantaged families should pay particular attention to these risks.

3. Key Principles of the DPDP Act Every NGO Should Understand

The DPDP framework is built around responsible and transparent processing of personal data.

A. Consent and transparency

Individuals should understand what personal information is being collected, why it is required and how it will be used.

For example, an NGO collecting a donor's name, email address and mobile number should clearly explain whether the information will be used for:

Processing and acknowledging donations.
Issuing donation receipts.
Sharing programme updates.
Sending newsletters and fundraising appeals.
Communicating future volunteering opportunities.

Consent for optional communications should not be confused with information required to complete a donation or deliver a service.

B. Purpose limitation

Personal data should be used for the specific purposes communicated to the individual.

For example, information collected to register a volunteer should not automatically be shared with unrelated organisations for their marketing activities.

C. Data minimisation

Collect only the information genuinely required.

If an NGO needs only a volunteer's name, mobile number and preferred activity, it should avoid collecting unnecessary personal details.

D. Accuracy of personal data

Organisations should take reasonable steps to ensure that personal information is accurate and updated, particularly when it is used to make decisions or shared with other organisations.

E. Storage limitation

Personal data should not be retained indefinitely without a valid purpose.

NGOs should establish appropriate retention and deletion policies, taking into account applicable legal, accounting, tax and statutory record-keeping requirements.

F. Security safeguards

Organisations must protect personal information against unauthorised access, disclosure, alteration and loss.

This includes appropriate access controls, encryption, secure backups, authentication and vendor security practices.

G. Accountability

The organisation responsible for deciding why and how personal data is processed must take responsibility for complying with applicable data protection obligations.

Delegating IT operations to a technology provider does not automatically remove the organisation's responsibilities.

4. Who Is Responsible Under the DPDP Act?

Two important terms under the Act are particularly relevant to NGOs.

Data Principal: The individual whose personal data is being processed. This could be a donor, volunteer, beneficiary, employee or website user.

Data Fiduciary: The person or organisation that determines the purpose and means of processing personal data.

For example, if an NGO independently collects donor information through its website and decides how to use it, the NGO will generally act as the Data Fiduciary.

A technology service provider processing that information on the NGO's instructions may act as a Data Processor.

A digital fundraising platform may also have its own Data Fiduciary responsibilities, depending on the purposes and means of processing it determines.

Therefore, NGOs should clearly define responsibilities when working with:

Website and application developers.
CRM and cloud service providers.
Payment gateways.
Digital marketing agencies.
Fundraising platforms.
External data management agencies.

Written agreements should address data security, permitted processing, confidentiality, breach reporting, deletion and assistance with individuals' rights.

5. What Do the DPDP Rules 2025 Mean for NGOs?

The DPDP Rules, 2025, provide practical requirements for implementing the Act.

Some particularly important areas for non-profits include the following.

A. Clear and independent privacy notices

Organisations should provide privacy notices in clear and understandable language.

A privacy notice should explain:

What personal data is collected.
The specific purposes for collecting and processing it.
How individuals can withdraw consent.
How individuals can exercise their rights.
How complaints can be submitted.

A general statement buried within lengthy website terms and conditions may not be sufficient.

B. Consent management

Organisations should maintain appropriate records of consent and ensure that consent can be withdrawn through an accessible mechanism.

Withdrawal of consent should be as easy as giving consent.

For example, if a donor subscribes to an NGO's newsletter, the organisation should provide a straightforward unsubscribe mechanism.

C. Data breach notification

The Rules establish requirements for notifying affected individuals and the Data Protection Board of India in the event of a personal data breach.

Organisations should establish an incident response procedure that enables them to identify, contain, investigate and report breaches within the applicable timelines.

D. Reasonable security safeguards

The Rules require appropriate technical and organisational safeguards, including measures relating to data security, access management, monitoring and protection against unauthorised access.

E. Children's personal data

Additional safeguards apply when processing children's personal data.

The Act generally requires verifiable parental or lawful guardian consent before processing a child's personal data, subject to specified exemptions.

This is particularly relevant to NGOs working in education, child welfare, healthcare and community development.

F. Data retention and deletion

Organisations should review how long personal data is retained and establish procedures for erasure when it is no longer needed for the specified purpose, unless retention is required by law.

6. Is There Any Exemption for NGOs?

This is an important question for the non-profit sector.

The DPDP Act does not provide a blanket exemption simply because an organisation is registered as a charitable trust, society or Section 8 company.

An NGO should not assume that its charitable or social welfare objectives automatically place it outside the Act.

However, the legislation does provide certain exemptions for specified circumstances and purposes.

For example:

Processing of personal data for research, archiving or statistical purposes may qualify for an exemption when the statutory conditions and prescribed standards are met.
Certain personal or domestic processing activities are outside the scope of the Act.
Specific exemptions may apply to certain legally recognised purposes and circumstances.

An NGO conducting research, surveys or social impact assessments should examine whether a particular exemption is applicable rather than assuming that all its activities qualify.

The exemption analysis should be activity-specific and supported by appropriate documentation.

7. DPDP Compliance Roadmap for NGOs

Non-profits need not approach compliance as an expensive technology transformation. A structured and proportionate approach can help even smaller organisations prepare effectively.

The following roadmap provides a practical starting point.

Step 1: Conduct a personal data audit

Prepare an inventory of all personal information collected and maintained by the organisation.

Identify information relating to:

Donors and supporters.
Volunteers and members.
Beneficiaries.
Employees and trustees.
Corporate and CSR partners.

Document where the information is collected, where it is stored, who can access it and with whom it is shared.

Step 2: Review website privacy policies

Review the organisation's website, donation forms, volunteer registration forms and newsletter subscriptions.

Ensure that privacy notices are clear, accessible and aligned with actual data-processing practices.

Step 3: Introduce consent mechanisms

Provide appropriate consent mechanisms at the point of data collection.

Avoid pre-ticked consent boxes and bundled permissions for unrelated purposes.

Maintain records of consent and withdrawal wherever required.

Step 4: Strengthen data security

Implement basic but effective security controls:

Strong passwords and multi-factor authentication.
Role-based access to donor and beneficiary databases.
Encryption of sensitive information.
Secure backups.
Regular software updates.
Restricted access to financial and identity documents.
Periodic security assessments.

Step 5: Establish a data retention policy

Define how long different categories of personal data should be retained.

For example, donation records may need to be maintained for statutory accounting and tax purposes, while old volunteer enquiries may no longer need to be retained after their purpose has been fulfilled.

Deletion policies should respect applicable legal retention obligations.

Step 6: Review third-party service providers

Examine agreements with payment gateways, hosting providers, CRM providers, cloud platforms and marketing agencies.

Establish clear responsibilities for data processing, security, confidentiality and breach reporting.

Step 7: Prepare a data breach response plan

Every NGO should know what to do if donor records, beneficiary information or volunteer databases are compromised.

The plan should identify responsible persons, escalation procedures, investigation steps, communication responsibilities and applicable regulatory reporting requirements.

Step 8: Train employees and volunteers

Data protection is not exclusively an IT responsibility.

Anyone accessing donor records, beneficiary information or volunteer databases should understand basic privacy and security practices.

8. Special Considerations for Digital Fundraising Platforms

Digital fundraising platforms are becoming an important part of India's social impact ecosystem.

They enable donors to discover verified NGOs, contribute to charitable causes, receive donation acknowledgements and track the impact of their contributions.

However, these platforms may process personal information belonging to multiple stakeholder groups simultaneously.

A responsible digital fundraising platform should consider:

Donor privacy: Protect donor identities, contact details and donation histories.
NGO data protection: Ensure that NGO representatives' information is handled appropriately.
Beneficiary privacy: Avoid publishing identifiable beneficiary information without an appropriate lawful basis and safeguards.
Payment security: Work with authorised payment service providers and avoid unnecessarily storing card or banking credentials.
Controlled data sharing: Ensure that donor information is not shared with NGOs or other parties beyond the disclosed and permitted purposes.
Transparency: Explain how the platform collects, processes and shares personal information.

A platform connecting donors, NGOs, volunteers and corporates must carefully evaluate its role as a Data Fiduciary or Data Processor for each processing activity.

This is especially important where the platform determines its own purposes for analytics, marketing, user engagement or other services.

9. DPDP Implementation Timeline: What Should NGOs Know?

The Government has adopted a phased implementation approach.

The final Rules were notified on 14 November 2025, with different provisions becoming effective at different stages.

Timeline	Implementation
14 November 2025	Specified institutional, definitional and administrative provisions came into force
13 November 2026	The one-year provisions, including Rule 4 concerning Consent Manager registration and obligations, are scheduled to come into force
13 May 2027	The principal operational provisions, including most Data Fiduciary obligations and the corresponding Rules, are scheduled to come into force

The exact commencement of individual provisions should be checked against the Gazette notifications.

For NGOs, the practical message is clear: preparation should begin now rather than waiting until the final compliance date.

10. What Happens If an Organisation Fails to Comply?

The DPDP Act provides for financial penalties for specified contraventions.

Depending on the nature of the violation, penalties can be substantial. The maximum penalty for failure to take reasonable security safeguards to prevent a personal data breach can extend to ₹250 crore. Other contraventions also carry significant financial penalties.

These are statutory maximums, not automatic penalties for every incident.

The Data Protection Board of India is responsible for handling relevant proceedings under the Act.

For non-profits, the consequences may extend beyond financial penalties to loss of public confidence, donor relationships and institutional credibility.

It is therefore important to recognise data protection as an organisational governance issue.

11. A Practical DPDP Readiness Checklist for NGOs

Every NGO, trust, foundation and non-profit organisation can use the following checklist to assess its readiness.

Identify all categories of personal data collected.
Map how donor, volunteer and beneficiary information is used.
Review website privacy policies and consent notices.
Establish appropriate consent and withdrawal mechanisms.
Define data retention and deletion policies.
Restrict access to personal information.
Implement suitable technical security safeguards.
Review third-party service provider agreements.
Establish a data breach response procedure.
Train employees, trustees and volunteers.
Review procedures for handling individual data rights.
Assess special requirements relating to children's data.
Document compliance responsibilities and governance.

Conclusion: Data Protection Is an Extension of Social Responsibility

Non-profit organisations exist to serve society, support vulnerable communities and create positive social change.

Their responsibilities should extend beyond delivering programmes and mobilising donations. They must also protect the trust that individuals place in them when sharing their personal information.

The DPDP Act 2023 and DPDP Rules 2025 provide an opportunity for India's non-profit sector to strengthen its governance, improve transparency and build a more trustworthy digital ecosystem.

For NGOs, compliance should not be treated as a last-minute legal exercise. It should become an integral part of organisational culture, technology management and stakeholder engagement.

Trust is the foundation of every successful social initiative. Protecting personal data is one more way of protecting that trust.

As India's digital social impact ecosystem continues to grow, organisations that embrace responsible data practices will be better positioned to build lasting relationships with donors, volunteers, beneficiaries and corporate partners.

A Call to Action

Whether you are an NGO, charitable trust, donor, volunteer or corporate CSR professional, take the first step towards responsible data management.

Review your organisation's data practices, understand your obligations and start building a privacy-conscious culture.

At Inpas, we believe that connecting empathy and creating impact must go hand in hand with transparency, accountability and trust.

Disclaimer: This article is intended for general awareness and educational purposes. It is not legal advice. Applicability, exemptions, commencement dates and compliance requirements should be assessed against the latest official notifications and the specific activities of each organisation. NGOs should consult qualified legal and data protection professionals for organisation-specific guidance.

References and Further Reading

Digital Personal Data Protection Act, 2023 – Government of India: https://www.indiacode.nic.in/
Digital Personal Data Protection Rules, 2025 – Ministry of Electronics and Information Technology: https://www.meity.gov.in/
Gazette Notification G.S.R. 843(E), 13 November 2025 – Commencement of DPDP Act provisions.
Gazette Notification G.S.R. 846(E), 13 November 2025 – Digital Personal Data Protection Rules, 2025.
Ministry of Electronics and IT – DPDP Rules and implementation timeline: https://www.meity.gov.in/documents/act-and-policies/digital-personal-data-protection-rules-2025-gDOxUjMtQWa

Important publication note (6 November 2026): The one-year implementation milestone is just around the corner, on 13 November 2026. The main operational provisions are scheduled for 13 May 2027. This makes the subject particularly timely for publication now.

E-Gazette+2

Official reference material:

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