Comments on Draft DPDP Rules 2025

On February 14, 2025, Common Cause submitted its recommendations for the Draft Personal Data Protection (DPDP) Rules, 2025. The recommendations highlighted the various shortcomings that were prevalent in the Rules and sought for the much-needed clarity, specificity, and use of proper language to relieve the Rules of any existing ambiguities. The recommendations highlighted some glaring powers that have been granted by the Rules, such as the excessive surveillance of children, lack of a grievance redressal mechanism, Central Government’s control over the Data Protection Board, and the government’s power to call for any information from a Data Fiduciary. A general comment on the crippling effect of the DPDP Act 2023, via the amendment made to Section 8(1)(j) of the Right to Information Act, 2005, was also included in our recommendations to voice out the overwhelming concern shared by civil society organizations across the country of the Right to Information Act being transformed to the “Right to Denial of Information Act”.

The recommendations submitted by us can be accessed here.