Recovery is where data-misuse and harassment risks peak, and where agents become your processors.
In short
Recovery is where data misuse and harassment risks peak. The Act makes recovery agents your processors, limits how borrower data is used, and gives borrowers rights, on top of RBI fair-practices rules. Penalties reach ₹250 crore.
What changes for this sub-sector.
In-house and outsourced recovery agents process borrower data on your behalf; their conduct is your liability.
Contact and location data may be used to recover a debt, not to pressure, shame or contact third parties.
No scraping contacts or call logs to trace borrowers; that breaches both the Act and RBI norms.
Borrowers can seek access, correction and erasure once a matter is closed.
Report data breaches to the Board; misuse in recovery invites both DPDP and RBI action.
Fix agent contracts and purpose limits first.
The readiness check surfaces agent-liability, purpose and minimization gaps.
Take the readiness check →