Readiness assessment
The Act
The DPDP Act, explainedThe DPDP Rules 2025

Ch IPreliminary

S.1 Short title and commencementS.2 DefinitionsS.3 Application and scope

Ch IIObligations of Data Fiduciary

S.4 Grounds for processingS.5 NoticeS.6 ConsentS.7 Certain legitimate usesS.8 Data Fiduciary obligationsS.9 Children’s dataS.10 Significant Data Fiduciary

Ch IIIRights and duties of Data Principal

S.11 Right to accessS.12 Correction and erasureS.13 Grievance redressalS.14 Right to nominateS.15 Duties of the Data Principal

Ch IVSpecial provisions

S.16 Transfer outside IndiaS.17 Exemptions

Ch VData Protection Board of India

S.18 Establishment of the BoardS.19 Composition of the BoardS.20 Salary and term of officeS.21 DisqualificationsS.22 Resignation and vacanciesS.23 Proceedings of the BoardS.24 Officers and employeesS.25 Members as public servantsS.26 Powers of the Chairperson

Ch VIBoard powers and procedure

S.27 Powers and functions of the BoardS.28 Procedure followed by the Board

Ch VIIAppeal and dispute resolution

S.29 Appeal to the Appellate TribunalS.30 Tribunal orders as a decreeS.31 Alternate dispute resolutionS.32 Voluntary undertaking

Ch VIIIPenalties

S.33 Penalties and the ScheduleS.34 Penalties to Consolidated Fund

Ch IXMiscellaneous

S.35 Good-faith protectionS.36 Power to call for informationS.37 Blocking of accessS.38 Consistency with other lawsS.39 Bar of jurisdictionS.40 Power to make rulesS.41 Laying of rules before ParliamentS.42 Power to amend the ScheduleS.43 Power to remove difficultiesS.44 Amendments to other Acts
Industries
Fintech & BFSIPayments & UPIUPIWalletsLendingBNPLLSPsKYCVideo-KYCAadhaar eKYCWealthtechInsurTechHealth insuranceDebt collectionsBanksNBFCsNGOsHealthcare & PharmaHospitalsDiagnostic labsGenetic testingPharmaClinical trialsTelemedicineE-commerce & RetailD2CMarketplacesLogisticsLoyalty & CRMGCCsSaaS & TechnologyAI & MLFoundation modelsB2B SaaSCloudDeveloper toolsEdTech & EducationSchoolsCoachingLMSProctoringChildren-directed appsGovernment & PSUe-GovernancePublic servicesUtilitiesManufacturingAutomotiveDealersIndustrialIoTMedia & EntertainmentAdTechGamingOTTPublishingSocial mediaBrowse all sectors
Implementation
All 17 DPDP servicesFintech & digital lendingGCC & global centresDPDP Compliance AssessmentFind where you stand and your gapsDPDP ImplementationTurn the rules into daily practiceData MappingKnow what data you hold, and whereRoPAYour record of processing activitiesPrivacy AuditIndependent check of your controlsDPO ServicesOutsourced or part-time DPOSDF ReadinessCheck for extra SDF dutiesConsent ManagementCapture, track and withdraw consentNotice & Consent RemediationFix notices and consent flowsData Principal RightsHandle access, correction, erasureRetention & DeletionWhat to keep, how long, how to deleteVendor & Processor ManagementControl third parties handling dataChildren's DataRules for handling minors' dataSecurity SafeguardsTechnical and organisational controlsBreach ResponseWhat to do when a breach happensPrivacy Operations SupportKeep the programme runningDPDP TrainingTrain staff, legal and leaders
Training
All DPDP Act trainingEmployee awarenessCorporate trainingLeadership briefingDPO and certification
Resources
Readiness assessmentGuidesBy roleGlossaryCompareNews
About
AboutEditorial policyContactFAQ
Readiness assessment
Share this section

Chapter V · Data Protection Board of India

Section 25: Members and officers to be public servants

Section 25 treats the Board's Chairperson, Members, officers and employees as public servants under the Penal Code when acting under the Act.

Official text
Section 25Public-servant status
Chapter
Chapter V · Data Protection Board of India
Status
In force
In force since
13 November 2025
Applies to
Data Protection Board
Official citation
DPDP Act, 2023, s.25
Reading time
2 min
Updated
August 2026

At a glance

Section 25 deems the Chairperson, Members, officers and employees of the Board to be public servants within the meaning of Section 21 of the Indian Penal Code when acting or purporting to act under the DPDP Act. This brings them within public-servant accountability and protection provisions. This section is in force since 13 November 2025.

Applies to The BoardChapter Chapter VEffective 13 Nov 2025Read time 2 min

Section 25: key takeaways

  • Board members and staff are public servants under Section 21 of the Penal Code when acting under the Act [25].
  • This attaches public-servant duties and protections to their official acts.

Who Section 25 applies to

Read this only for completeness; it defines the legal status of Board officials and has no direct company obligation.

FoundersLegal / DPOCompliance leadsProduct / engineering

Section 25 in plain language

Section 25 gives the Board's people public-servant status for their official work, which carries both accountability, offence provisions apply to them, and legal protection for acts done in good faith.

Section 25 of the DPDP Act: full text

Section 25: Members and officers to be public servants

25 The Chairperson, Members, officers and employees of the Board are deemed to be public servants within the meaning of Section 21 of the Indian Penal Code when acting or purporting to act under the Act.

Wording summarised from the enacted Act. Always confirm against the official Gazette text for authoritative language.

What Section 25 means for your business

  • No company action; it defines the legal status of the officials handling your matters, relevant if you ever allege misconduct or rely on their official acts.

Frequently asked questions about Section 25

Are Board members public servants?
Yes, when acting under the Act they are deemed public servants under Section 21 of the Indian Penal Code.
Why does public-servant status matter?
It brings their official acts within both the accountability and the protection framework for public servants.

Sources

Related sections
Section 24: Officers and employeesSection 26: Powers of the ChairpersonSection 35: Protection of action in good faithChapter V overview

This is an educational explanation, not legal advice. dpdpactindia.in is an independent resource and is not affiliated with the Government of India.

Start readiness assessment