Ensuring Trust and Compliance: Navigating the DPDP Act for Non-Profit Organizations

The introduction of the Digital Personal Data Protection Act, 2023 (DPDP Act) marks a pivotal moment for personal data governance in India. While the Act was introduced from 11 August 2023 onwards, notified on 14th November 2025, its provisions establish a mandatory framework for handling the digital personal data of individuals.

Non-Governmental Organizations (NGOs) are particularly affected, as their mission-critical work often involves collecting and processing sensitive beneficiary data, making robust compliance essential for maintaining community trust and operational longevity.

Part I: Overview and Applicability of the DPDP Act

A. Scope and Definitions

The DPDP Act is applicable to any person who determines the purpose and the means of processing the digital personal data of an individual.

1. Personal Data Defined: Personal data is defined as data through which an individual can be identified or which relates to the individual. Examples include an individual’s name, age, date of birth (DOB), address, school attendance records, and test scores.

2. Data Format: The Act covers personal data collected in a digitized form. It also applies to data that was collected initially in a non-digitized form but was subsequently digitized.

   
   

B. Exceptions

The regulations provide certain legitimate uses for which personal data can be processed, some of them are as under

• For the specified purpose for which the individual has voluntarily provided his/her personal data and in respect of which he/she has not indicated that he/she does not consent to the use of his/ her personal data.

• For responding to medical emergency involving a threat to the life

• Processing necessary to ensure the safety of a person during events such as a disaster or epidemic.

Part II: Key Compliance Checkpoints for NGOs

NGOs must address several critical areas to ensure they meet the mandatory requirements of the DPDP Act:

1. Consent and Purpose Limitation

• Mandatory Consent: NGOs must seek written, clear, specific, unconditional, and voluntary consent from beneficiaries before data collection. This requirement specifically extends to the onward sharing of this data with donors.

• Purpose Limitation: The NGO must inform the beneficiary about the exact purpose for which the data is being sought. The collected data must then be used only for that same limited purpose, such as project monitoring or impact assessment.

  
  

2. Data Security Measures

Robust data security measures are required to protect beneficiary data, some of them are as under:

• Data Sharing Protection: NGOs must apply encryption or a password before sharing data with donors.

• PII Masking: Personally Identifiable Information (PII) must be masked if required.

• System Tracking: Mechanisms must be implemented to restrict and track computers used for data processing.

• Access Logs: NGOs must maintain detailed file access logs. These logs must record who accessed the data, when, and why.

  
  

3. Governance and Accountability

• Staff Training: NGOs are required to train and sensitize staff on appropriate data handling procedures.

• Data Protection Officer (DPO): An organization must appoint a Data Protection Officer to ensure compliance with the DPDP Act.

  
  

4. Data Deletion and Record Keeping

• Withdrawal of Consent: A mechanism must be created for data deletion if a beneficiary chooses to withdraw their consent.

• Record Maintenance: NGOs must maintain records for both consent requests and withdrawal requests.

• Deletion Acknowledgment: When data is shared with donors, and subsequently deleted upon request, the NGO must keep the deletion certificate or acknowledgment from the donor as a record.

  
  

5. Handling Children's Data

For individuals under the age of 18 years (children), parental or guardian consent is mandatory for data processing. The law also enforces other restrictions related to children’s data.

Part III: Strategic Assistance from Management Consulting Firms

A management consulting firm specializing in CSR and social sector consulting can leverage its expertise to transition NGOs from awareness of the DPDP Act to complete, practical compliance. CSR consulting firms assist in operationalizing legal mandates, focusing on data governance, process design, and staff capacity building.

The following table details key compliance areas and the corresponding support provided by a specialized CSR consulting services firm:

DPDP Compliance Requirement (Source)	How Consultants Assist NGOs in Compliance
Governance and Training: Appoint DPO; Train and sensitize staff	Defining Data Protection Infrastructure: Consultants define the specific role and operational responsibilities of the DPO within the NGO structure. They design and deliver bespoke training and sensitization programs for all staff based on their specific roles in data handling.
Consent and Purpose: Seek written, voluntary consent; Inform and adhere to limited purpose	Consent Protocol Design: Firms develop standardized, legally compliant consent templates, ensuring clarity on data use (e.g., project monitoring or impact assessment). They also establish robust procedures for managing mandatory parental or guardian consent for minors (under 18).
Security Implementation: Apply encryption/password protection; Mask PII; Track systems; Maintain access logs	Security Assessment and Implementation: Consultants audit existing IT security and implement necessary technical measures, such as defining protocols for mandatory encryption or password protection before sharing data with donors. They also create auditable systems for restricting and tracking computers and generating mandated file access logs (recording who accessed, when, and why).
Deletion and Record Keeping: Create mechanism for deletion upon withdrawal of consent; Maintain records; Keep donor deletion acknowledgements	Data Lifecycle Management: Firms design and implement the required mechanism for data deletion upon a beneficiary’s withdrawal of consent. They set up systematic record-keeping processes to track all consent and withdrawal requests and establish a mandatory protocol for securing and filing the necessary deletion certificate or acknowledgment from the donor.

Conclusion

By structuring these complex requirements, specialized consulting firms ensure that compliance with the DPDP Act is not viewed as a constraint, but rather as an institutional mechanism to enhance accountability and build deeper trust with the vulnerable communities NGOs serve. This structured approach transforms abstract legal risk into a manageable, operational blueprint, allowing the NGO to focus its resources on achieving its core mission.