s.2 · s.3
Digital personal data
Digital personal data is personal data in digital form, which is the only form the DPDP Act regulates.
The Act does not reach paper records that stay on paper. It reaches every record on a phone, a laptop, a server or a cloud service, and every paper record that a business later scans, photographs or types up.
In practice almost every business record qualifies. A visitor register kept in a spreadsheet, a WhatsApp conversation with a client, an intake form on a website: all digital, all personal data, all in scope.
Questions people ask
- If we keep client files only on paper, does the Act apply?
- Not to those files, until any of them is digitised. Most firms digitise at least something, and that something is in scope.
- Does a photo of a document count as digitised?
- Yes. Section 3 refers to data collected in non-digital form and digitised subsequently, which includes photographing it.
Related terms
The DPDP brief
One email a month. What moved in the Act, and what our scans found.
Every claim cited to its section, the same way these pages are. No product news, no roundups of other people’s blogs.