Data protection · Provision

Section 12, DPDP Act 2023 — Correction, Completion and Erasure

Section 12, Digital Personal Data Protection Act, 2023

A Data Principal may require her data to be corrected, completed, updated or erased, and erasure is refused only where a law requires keeping it.

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What the section does

  • A Data Principal has the right to correction, completion, updating and erasure of her personal data, for processing to which she has previously given consent.
  • On receiving a request, the Data Fiduciary must correct inaccurate or misleading personal data, complete data that is incomplete, and update data that is out of date.
  • On a request for erasure, the Data Fiduciary must erase the personal data unless retention is necessary for the specified purpose or for compliance with any law in force.
  • The right runs against the Data Fiduciary that holds the data, which is why section 8 requires it to be able to say what it holds and why.

On refusing a valid request

a breach of the Act. Retention has to be justified by the specified purpose or by a law. A general preference for keeping records is neither.

Where people go wrong

  • Refusing erasure because the data might be useful later. The exception is retention necessary for the purpose or required by law, not retention that would be convenient.
  • Correcting the record in one system and leaving it stale in the others. The obligation attaches to the personal data, not to whichever database was easiest to reach.
  • Treating a correction request as a complaint to be closed. It is a statutory right with a statutory response.
  • Asking the person to prove the data is wrong before acting. The section requires correction of inaccurate or misleading data on request.

Common questions

Can a customer require a business to delete their personal data?

Yes. Section 12 gives a Data Principal the right to erasure, and the Data Fiduciary must erase unless retaining the data is necessary for the specified purpose or for compliance with a law in force.

What is the difference between erasure under section 12 and under section 8?

Section 12 is a right the Data Principal exercises by making a request. Section 8 imposes a duty to erase once consent is withdrawn or the purpose is no longer served, whether or not anybody asks.

Can a business refuse to correct data it believes is accurate?

The section requires correction of inaccurate or misleading data on request. A dispute about accuracy does not remove the obligation to deal with the request, and the grievance route under section 13 remains open to the person.

Act on this

  • Erasure confirmation letter
  • Section 11 — the right of access
  • Section 13 — grievance redressal

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.