Data protection · Provision

Section 11, DPDP Act 2023 — Data Principal Rights: Access, Correction, Erasure, Nomination

Section 11, Digital Personal Data Protection Act, 2023

A person whose data you hold can ask what you hold, demand corrections, request erasure, and nominate someone to exercise rights after their death. Section 11 is the DSAR section.

Quick Statutory Answer

Section 11 of the DPDP Act 2023 empowers Data Principals to exercise statutory rights including obtaining a summary of personal data processed, identities of all fiduciaries with whom data is shared, requesting correction of inaccurate data, and demanding erasure when the purpose ends. It also provides the right to nominate another individual to exercise rights upon death or incapacity.

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What the section does

  • A Data Principal may ask a Data Fiduciary for a summary of the personal data it holds, the processing activities undertaken, and the identities of other Data Fiduciaries with whom data has been shared.
  • A Data Principal may request correction of inaccurate personal data, completion of incomplete data, and erasure of data no longer needed for the stated purpose.
  • A Data Principal may nominate another person to exercise these rights after their death or incapacity.
  • The Data Fiduciary must respond within the period and in the manner prescribed by the Rules.

Data Principal Rights Under Section 11 DPDP Act (DSAR Matrix)

Data Principal Rights Under Section 11 DPDP Act (DSAR Matrix)
Right Statutory Scope (Section 11) Fiduciary Obligation Statutory Response Limit
Right to Access Summary Summary of personal data held & processing activities Provide readable summary without disclosing trade secrets Within period prescribed by Rules
Identities of Shared Parties Names of third-party fiduciaries given data access Disclose all fiduciaries with whom data was shared Within period prescribed by Rules
Right to Correction Rectify inaccurate, misleading or incomplete data Update records across databases and notify processors Within period prescribed by Rules
Right to Erasure Delete personal data no longer needed for purpose Erase data across all systems unless required by law Within period prescribed by Rules
Right to Nominate Appoint representative for death or incapacity Record nominee and honour authorised requests On verification of nominee status

On non-response

Board complaint. A Data Principal whose request is not responded to may complain to the Data Protection Board.

Where people go wrong

  • Ignoring or delaying a data access request beyond the prescribed period.
  • Refusing erasure on the ground the data might be useful later.
  • Sharing raw internal records rather than a summary as section 11 specifies.
  • Confusing erasure on request (s.11) with erasure on consent withdrawal (s.8).

Common questions

What is the right of access under the DPDP Act 2023?

Section 11 of the Digital Personal Data Protection Act, 2023 gives a Data Principal the right to ask a Data Fiduciary for a summary of the personal data it holds, the processing activities, and the other Data Fiduciaries with whom the data has been shared. This is the statutory basis for a Data Subject Access Request (DSAR) in India.

What is a DSAR under the DPDP Act?

A Data Subject Access Request — a request from a Data Principal under section 11 of the DPDP Act, 2023 for access to the personal data a Data Fiduciary holds about them, the purposes for which it processes it, and the entities it has shared it with. The Data Fiduciary must respond within the period prescribed by the Rules.

Can a person ask a company to delete their data under the DPDP Act?

Yes. Section 11(3) gives a Data Principal the right to request erasure of personal data where it is no longer necessary for the purpose of collection. The Data Fiduciary must erase it unless a law requires retention.

How long does a company have to respond to a DSAR under the DPDP Act?

Within the period prescribed by the DPDP Rules, 2025. The Rules set the response timeline. Businesses should treat it as a short statutory deadline — the Board enforces it on complaint.

What is the right to correction under the DPDP Act?

Section 11(2) gives a Data Principal the right to request correction of inaccurate or misleading personal data and completion of incomplete data. The Data Fiduciary must make the correction within the prescribed period.

Does the DPDP Act give the right to data portability?

Not expressly. Section 11 gives rights of access, correction, erasure and nomination. The Act does not replicate GDPR Article 20, though the Rules may prescribe a delivery format that enables portability in practice.

Can someone exercise DPDP rights on behalf of a deceased person?

Yes. Section 11(4) allows a Data Principal to nominate another person to exercise their rights after their death or incapacity. The Data Fiduciary must honour a valid nomination.

Act on this

  • DSAR response template (DPDP Act s.11)
  • Data erasure confirmation letter
  • Section 6 — how consent can be withdrawn
  • Section 8 — Data Fiduciary duties
  • Free DPDP readiness check

About this summary

A plain-English summary of what this provision requires, not a reproduction of it and not legal advice. Read alongside the bare Act, and take advice on anything turning on your own facts.