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
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Readiness assessment
Healthcare & Pharma · Pharma · Clinical trials

The DPDP Act for Clinical Trials & CROs

Trials and CROs process participant health data under the New Drugs and Clinical Trials Rules and ICMR ethics, plus the DPDP Act.

In short

Clinical trials operate under the New Drugs and Clinical Trials Rules, 2019, CDSCO oversight and ICMR ethics, with the DPDP Act layered on. Ethics-committee trial consent is not DPDP consent; you need both, and de-identification is your best defence. Penalties reach ₹250 crore.

Core impacts

What changes for this niche, and the specific rule it turns on.

Two consents, not one

Informed consent for the trial under the NDCT Rules and ICMR ethics does not replace DPDP consent for processing personal data; obtain both.

De-identify by default

Pseudonymise or anonymise participant data wherever the science allows to cut exposure.

Pharmacovigilance is in scope

Adverse-event and safety data still contain personal data and fall under the Act.

Cross-border, sectoral rules bite

Sponsors and CROs abroad are processors; the DPDP cross-border default is permissive, but sectoral and ethics rules still apply.

Long retention, documented

Trial-record retention runs for years; reconcile it with erasure and document the legal hold.

Common questions

Short, cite-able answers, mirrored in FAQPage schema.

Is trial consent the same as DPDP consent?
No. Ethics-committee informed consent covers the trial; DPDP consent covers processing personal data. You need both.
Can trial data be sent to a sponsor abroad?
Yes, as processing by a processor; the DPDP cross-border default permits it, but NDCT, ICMR and contractual controls still apply.
How long must trial data be kept?
For the long periods the NDCT Rules and ICMR require; the erasure right yields to that documented legal obligation.

Check your trial data.

The readiness check flags consent, de-identification and cross-border gaps.

Take the readiness check →