Data principal
s.2(j)The person the data is about. For a child, it includes the parent or lawful guardian.
This page explains how India's Digital Personal Data Protection Act, 2023 bears on AI systems, and what BiltIQ's platform does about it. Owning the platform on your servers, the Agent OS platform gate and approval records reduce what you must account for. Consent, notices, rights requests and breach reporting stay the buyer's duty. It is not legal advice.
This is an explainer, not legal advice. Confirm your obligations with qualified counsel.
The person the data is about. For a child, it includes the parent or lawful guardian.
The organisation that decides why and how personal data is processed. It answers for the processing.
An organisation that processes personal data on a data fiduciary's behalf.
A body registered with the Data Protection Board that lets a person give, manage, review and withdraw consent through one platform.
A data fiduciary the central government notifies, looking at factors such as the volume and sensitivity of the data and the risk to people's rights.
Anyone who has not turned 18.
Process personal data only for a lawful purpose: with the person's consent, or for one of the legitimate uses the Act lists. Every request for consent comes with, or after, a notice of what data is used and why.
People can get a summary of their data and how it is processed, have it corrected or erased, withdraw consent as easily as they gave it, nominate someone to act for them, and raise grievances.
Take reasonable security safeguards to prevent a personal-data breach, including for processing done by a data processor.
Tell the Data Protection Board of India and each affected person about a personal-data breach, in the form the DPDP Rules set.
The data fiduciary answers for processing done on its behalf. It may use a data processor only under a valid contract, and must have it erase data when the purpose ends or consent is withdrawn.
Get verifiable consent from a parent or lawful guardian before processing a child's data. Do not process it in a way likely to harm the child's well-being, and do not track, behaviourally monitor or target advertising at children. The DPDP Rules list limited exemptions, for example for educational institutions.
Organisations the government notifies carry extra duties: a Data Protection Officer based in India, an independent data auditor, and periodic impact assessments and audits.
The duties come into force in phases under the DPDP Rules, and the Act sets penalties for breaches. Check the current timeline in the official DPDP Rules.
Your AI can keep the record. These decisions stay with you:
Where BiltIQ processes personal data for you, for example in a pilot on our servers or when we run Learning OS for a school, we act as your data processor: we process it on your instructions and under the contract, which sets the safeguards and when we erase the data. You remain the data fiduciary.
No, not in general. The Act lets the government restrict transfers of personal data to countries it notifies; it does not ban every transfer. The DPDP Rules let the government require Significant Data Fiduciaries to keep certain personal data in India, and set conditions on making personal data available to a foreign state. Sector rules can be stricter, so check your regulator's rules as well. On an Own-it Agent OS install, the files your AI reads stay on your own servers, whatever the rule.
No. Owning your AI on your own servers reduces what you must account for, because no cloud model provider sits in the model path. In BiltIQ Agent OS, the platform gate blocks outbound calls by default and high-consequence actions wait for approval. Consent, notices, rights requests, retention and breach reporting stay your duty under the DPDP Act, whichever vendor runs your AI.
The DPDP Act's duties come into force in phases under the DPDP Rules, and the Act sets penalties for organisations that breach them. Check the current timeline in the official DPDP Rules, or with qualified counsel. Organisations choosing a platform for their AI now are choosing the architecture they will have to account for.
It depends on the product. An Own-it Agent OS install blocks outbound calls by default. Business OS stores files in GCS or S3 and makes no Claude or OpenAI calls; its Kimi option is off by default. Learning OS keeps LMS files in AWS (India region), its Kimi quiz fallback is on by default and can be switched off, and AI Teacher embeddings, vision and voice default to cloud.
Before processing a child's data, the data fiduciary must obtain verifiable consent from a parent or lawful guardian, and must not track, behaviourally monitor or target advertising at children, subject to limited exemptions in the DPDP Rules. For BiltIQ's AI Tutor, the school or college is the data fiduciary; BiltIQ processes data for it. AI Teacher voice and embeddings default to cloud services today. This is not legal advice.
Bring one workload. We'll show you on a 30-minute call where your data would sit in each product, and what would stay your duty.
We'll walk you through it on sample data.