DPDP for the Administration department in Manufacturing

Reviewed by InfraVeritas360 ResearchFirst published 10 October 2026Last reviewed 11 October 2026

Sources: DPDP Act, 2023 and DPDP Rules, 2025 (MeitY) · Ministry of Labour and Employment (PIB) · India Code; PRS summary · PIB · Kerala Factories and Boilers Department (copy of the Rules)

Admin runs gates, security agencies, canteens, transport and hostels.

Written for: Administration department, Manufacturing. Open this seat in the interactive tool

What is different here

Factories hold more personal data than most people think: large workforces and contract labour, gate passes, biometrics, medical checks, dealers and distributors, and in some industries, consumers and farmers. Most of it is collected at the gate, the medical centre and the dealer counter, not in head office. DPDP does not change your safety or labour duties. It asks you to know what you hold about each person, keep it safe, use it only for the reason it was collected, and answer when someone asks.

The first four things to sort out

Put CCTV and gate notices up.
Set periods for footage and visitor registers.
Check security and canteen agency contracts.
Lock hostel records.

A worked example

Administration department

Hostel register at a garment unit

Week 1The hostel keeps home addresses and family phone numbers in an open register.
Week 2The register moves to a locked cabinet.
Week 3Old pages are listed for destruction.
AfterA notice is put up.

Evidence kept

Cabinet
Destruction list

Lock and set a period.

What others in the sector usually do. Visitor registers are moving to devices with automatic deletion.

Where it usually goes wrong, by organisation type

Organisation type	Hotspots
Chemicals and petrochemicals	Worker health surveillance records; Hazardous goods driver and transporter records; Emergency plan contact lists shared with authorities
Fertilisers	Farmer Aadhaar authentication at retailer PoS; Farmer lists from meetings and agronomy apps; Dealer and retailer KYC records
Automotive and auto components	Connected-vehicle location data; Dealer-shared buyer lists; Mechanic loyalty apps
FMCG and consumer goods	Contest and promotion entries; Retailer app data; Agency-held consumer lists
Steel, metals and mining	Township and hospital records; Contract labour biometrics; Resettlement records
Cement and building materials	Mason loyalty bank details; Driver records; Dealer KYC
Textiles and apparel	Auditor access to worker files; Hostel records; Agency-held worker data
Food processing and dairy	Farmer payment data; Collection centre registers; Consumer complaint records

8 questions the Administration department asks, answered in full

Emergency plans with contact lists shared with authorities: is that allowed?

Short answer: Yes, for the plan; share only what it needs

Yes. The chemical rules ask the occupier to prepare an on-site emergency plan and share it with the Authority, and crisis groups use plans to prepare district and local plans. Sharing names and phone numbers for this is a duty under law. Share only what the plan needs, keep the list current, and remove people who have left. The rules ask you to inform people outside the site about hazards; they do not ask you to build a register of residents, so keep any such list small.

From your seat: Administration department. Keep gate and control room copies in a closed folder, not on the wall.

What the law says

Section 7 covers duties under law and safety during a disaster. Section 8(3) asks for accurate data when it is shared. Section 8(5) needs safeguards for the copies. Section 7 · Section 8(3) · Section 8(5) · Rule 6 · Section 8(7) · Rule 8

Steps

List the personal data in the on-site plan: emergency team, key staff, contractors, authority contacts.
Remove what the plan does not need, such as home addresses.
Review the list after every mock drill and when people leave.
Send the plan to authorities through a channel you can show.
Keep old versions only as long as needed, then destroy.

Evidence to keep

Plan contact list with review date
Mock drill record
Transmission record
Old version destruction log

Common mistakes

Lists with staff who left years ago
Home addresses and family numbers in the plan
Copies left on notice boards at the gate

Contract workers, gate passes and biometrics: who is responsible for their data?

Short answer: You are, for data used at your plant; agencies act for you under contract

Your company decides why contract workers' data is collected at your plant: gate access, attendance, safety and the records the Labour Codes ask for. So for that data you are responsible, even when a manpower agency or contractor collects it. Agencies need a contract with data terms. Collect only what the gate and the law need, and delete biometric templates and photos when a worker leaves.

What the law says

Section 7 covers purposes of employment and duties under law. Section 8(1) keeps you responsible for processors. Section 8(7) asks for erasure when the purpose is over. Section 7 · Section 8(1)–(2) · Section 8(5) · Rule 6 · Section 8(7) · Rule 8 · Section 5 · Rule 3

Steps

List what is collected for each contract worker: ID, photo, biometric, bank details, medical fitness.
Remove what the gate and the Labour Codes do not need.
Give a short notice in the worker's language at enrolment.
Add a data schedule to every agency and contractor contract.
Delete templates and photos at exit; keep only the registers the law requires.

Evidence to keep

Enrolment field list with reasons
Notice in local languages
Signed agency data schedules
Exit deletion log

Common mistakes

Agencies keeping their own copies of Aadhaar cards
Templates of workers who left years ago
Worker lists shared with contractors on chat groups

What about CCTV, visitor registers and biometric attendance?

Short answer: Yes, with notice, limits and a deletion period

All three are personal data. Put a clear notice where people are recorded, collect only what you need at reception, keep footage and registers for a set period, and protect biometric templates carefully. Do not keep copies of ID documents unless you must.

From your seat: Administration department. Admin runs the cameras and the reception desk. Notices, retention and viewing rights are yours to fix.

Example in Manufacturing

Plant gates, canteens and hostels have CCTV and biometrics. Put up notices and set short periods.

What the law says

Section 5 needs notice. Section 8(5) needs safeguards. Section 8(7) needs erasure after the purpose. For staff, Section 7(i) can cover security and attendance. Section 5 · Rule 3 · Section 8(5) · Rule 6 · Section 8(7) · Rule 8 · Section 7

Steps

Put notices at CCTV points and reception, in the local language.
Ask visitors only for name, phone and whom they are meeting, unless security needs more.
Set a period for footage and registers, then delete.
Restrict who can view footage, and log viewing.
Check the vendor contracts for CCTV, guards and attendance systems.

Evidence to keep

Notices in place
Retention settings on the recorder
Viewing log

Common mistakes

Photocopying visitor IDs as routine
Footage kept until the disk fills
Biometric systems with vendor default passwords

Are contract and agency workers our responsibility?

Short answer: Yes, for the data you decide about

Their data is your responsibility when you decide why and how it is used, for example gate passes, attendance, biometrics and safety records. The agency holds payroll and personal files, so your contract with the agency must cover how it protects that data.

From your seat: Administration department. Guards, housekeeping and drivers are often agency staff. Their ID copies and gate records need care.

Example in Manufacturing

Plants often have more contract workers than employees; gate passes, biometrics and medical checks are yours to protect.

What the law says

Section 7(i) covers employment purposes. Section 8(1) and 8(2) make you responsible for processors such as manpower agencies working on your behalf. Section 7 · Section 8(1)–(2) · Section 8(5) · Rule 6

Steps

List what you hold about contract workers: ID copies, photos, biometrics, attendance, medical fitness.
Decide who is the Data Fiduciary for each item: you or the agency.
Put data terms in every manpower contract.
Give a short notice in the workers' language at the gate or induction.
Delete gate and ID records on a schedule.

Evidence to keep

Contract-worker data list
Agency contracts with data terms
Notice at the gate

Common mistakes

Photocopies of Aadhaar kept in open files
No terms in the agency contract
Biometric data with no deletion date

What must a vendor contract say about personal data?

Short answer: Yes, every vendor that touches personal data

You stay responsible for what your vendors do with personal data. The contract should say what data they get, for what purpose, the security they must keep, how fast they must tell you about an incident, that sub-contractors need your approval, and how data is returned or deleted at the end.

From your seat: Administration department. Security, housekeeping, transport and CCTV vendors all touch personal data. Their contracts need data terms.

Example in Manufacturing

Manpower agencies, contractors, canteen and medical centre operators, transporters, loyalty and telematics vendors.

What the law says

Section 8(1) keeps responsibility with you. Section 8(2) allows a processor only under a valid contract. Rule 6 asks for security terms in that contract. Section 8(1)–(2) · Section 8(5) · Rule 6 · Section 8(6) · Rule 7 · Section 8(7) · Rule 8

Steps

List vendors who receive or can see personal data.
Rank them by how much and how sensitive.
Add a data-protection schedule to each contract, starting with the top ten.
Ask for evidence: certificates, test results, deletion confirmations.
Review the top vendors every year.

Evidence to keep

Vendor register
Signed data-protection schedules
Annual review notes

Common mistakes

Relying on the vendor's standard terms
No incident-notice time
No exit and deletion clause

How long can we keep personal data?

Short answer: For the legal or business period, then erase

Keep data for as long as its purpose needs, or as long as a law requires, and then erase it. Every organisation must keep personal data and logs for at least one year under Rule 8(3). Write a retention schedule by record type, with the law or reason against each period.

From your seat: Administration department. Visitor registers, gate passes and paper files need a period and a shredding date.

Example in Manufacturing

Set periods from the Labour Codes, the chemical rules and the fertiliser order, record type by record type.

What the law says

Section 8(7) asks for erasure when the purpose is over, unless a law requires retention. Rule 8(3) sets a one-year minimum for personal data, traffic data and logs. Section 8(7) · Rule 8 · Section 8(5) · Rule 6

Steps

List the record types you hold.
Write the period for each, with the law, regulator rule or business reason.
Set a trigger for the period to start: end of relationship, date of transaction, exit date.
Automate deletion where you can; for paper, schedule shredding.
Keep a deletion log.

Evidence to keep

Retention schedule approved by Legal
Deletion log
Shredding or disposal certificates

Common mistakes

'Keep everything forever' because storage is cheap
Deleting before the legal minimum
Forgetting email, shared drives and backups

Something has gone wrong. What happens in the first 72 hours?

Short answer: Six hours for CERT-In; without delay for people and the Board; 72 hours for the detailed report

Contain it, then tell people. A reportable cyber incident goes to CERT-In within six hours of being noticed. Under DPDP, each affected person and the Data Protection Board must be told without delay, and the Board needs a detailed report within 72 hours. Sector regulators may have their own clock too.

From your seat: Administration department. A lost register or a stolen laptop is a breach. Call the DPO the same day.

Example in Manufacturing

A stolen gate server or a lost medical register is a breach. CERT-In's six hours and the DPDP steps may both apply.

What the law says

Section 8(6) and Rule 7 set the DPDP steps. The CERT-In Directions of 28 April 2022 set the six-hour report. A breach includes accidental disclosure and loss of access, not only hacking. Section 8(6) · Rule 7 · Section 8(5) · Rule 6

Steps

Name one incident lead and a back-up, with phone numbers that work at night.
Write the first-hour steps: isolate, preserve logs, tell the DPO and the incident lead.
Keep ready-made drafts for CERT-In, the regulator, the Board and affected people.
Decide in advance who signs off each message.
Rehearse once a year with the people who would actually be called.

Evidence to keep

Incident plan with clocks
Rehearsal record
Incident log with times of each step

Common mistakes

Waiting to finish the investigation before telling anyone
Treating a wrong email or a lost laptop as 'not a breach'
Only IT knowing the plan

What should our privacy notice say, and where must people see it?

Short answer: Yes, at every point where you collect data

A notice must tell people, in plain words, what data you collect, why, how they can withdraw consent, how they can use their rights and how they can complain to the Data Protection Board. It has to stand on its own, separate from long terms and conditions, and be shown at the point where data is collected.

From your seat: Administration department. Reception and gates are collection points. Put the short notice there.

Example in Manufacturing

Gate pass forms, contract worker enrolment, the medical centre, dealer and mason app sign-ups and warranty cards each need a short notice, in the language people use.

What the law says

Section 5 and Rule 3 ask for a notice that can be understood on its own, with an itemised list of the data and the purpose for each item. Data you already hold from before the Act also needs a notice, as soon as reasonably practicable. Section 5 · Rule 3 · Section 6 · Sections 11–14 · Rule 14

Steps

List every point where personal data comes in: forms, apps, counters, calls, emails, partner feeds.
Write one short notice per collection point, with the data items and purpose side by side.
Add how to withdraw consent, how to make a request and the DPO or contact person's details.
Offer the notice in English and in the languages your workers and customers actually use.
Keep each version with the date it went live.

Evidence to keep

Screenshots or copies of the notice at each collection point, with dates
Notice version history
Translations, where used

Common mistakes

Hiding the notice inside terms and conditions
One notice for everything, with no link between data items and purposes
Forgetting old data collected before the Act

The sections you will use most

Section 5 · Rule 3: Notice. Gate pass forms, contract worker enrolment, medical check forms, dealer onboarding, loyalty app sign-ups, warranty cards and connected-vehicle apps each need a short notice in the language people use.
Section 8(5) · Rule 6: Security safeguards. Biometric attendance, occupational health records and connected-vehicle data need strong access control. Keep plant control networks apart from systems holding personal data.
Section 8(7) · Rule 8: Erasure and retention. Labour Code and safety records stay for the legal period. Biometric templates, gate photos and visitor data of people who left should go much sooner.
Section 8(1)–(2): Responsibility for vendors. Manpower agencies, labour contractors, canteen and medical centre operators, transporters, loyalty vendors, telematics vendors and dealer software vendors all work for you on some data.

Other rules that sit alongside DPDP

Rule	What it says	What it means alongside DPDP	Source
Labour Codes (in force from 21 November 2025)	The Code on Wages, 2019, the Industrial Relations Code, 2020, the Code on Social Security, 2020 and the Occupational Safety, Health and Working Conditions Code, 2020 came into force on 21 November 2025. Together they rationalise 29 earlier labour laws.	Worker and contract labour records now follow the codes and the rules under them. Set retention for these records against the codes and state rules, not against the old Acts.	Ministry of Labour and Employment (PIB)
Occupational Safety, Health and Working Conditions Code, 2020	Subsumes earlier Acts including the Factories Act, 1948 and the Contract Labour (Regulation and Abolition) Act, 1970. Requires a free annual health examination for employees where prescribed, licences for those hiring contract labour, and registers kept in the prescribed form, electronically or otherwise.	Gate passes, attendance, contractor registers and medical checks are legal records. DPDP adds access limits, security and deletion when the legal period is over.	India Code; PRS summary
OSH Code: workers in hazardous processes	Pre-employment, periodic and post-exposure medical examinations are mandatory. Health records are mandatory and accessible to employees and inspectors. Hazardous establishments need an on-site emergency plan and six-monthly mock drills.	Health records are among the most sensitive data a plant holds. The worker and the inspector may see them; supervisors and the wider HR team should not.	PIB
Manufacture, Storage and Import of Hazardous Chemical Rules, 1989	Rule 13: the occupier prepares and keeps up to date an on-site emergency plan, with a mock drill every six months and the report made available to the Authority. Rule 14: the Authority prepares the off-site emergency plan. Rule 15: the occupier informs persons outside the site about the hazard and safety measures.	Emergency plans carry names and phone numbers of staff, contractors and authorities. Share them because the law asks, keep them current, and remove people who have left.	Kerala Factories and Boilers Department (copy of the Rules)
Chemical Accidents (Emergency Planning, Preparedness and Response) Rules, 1996	Set up Central, State, District and Local Crisis Groups. The District Crisis Group reviews occupiers' on-site plans while preparing the district off-site plan. The Local Crisis Group prepares the local emergency plan for the industrial pocket, educates the population likely to be affected and answers public inquiries.	Contact lists you give the crisis groups are shared for a legal duty. Send only what the plan needs, through a channel you can show.	FAOLEX (text of the Rules)
Direct Benefit Transfer in fertilisers (Department of Fertilizers)	Sale of all subsidised fertilisers to farmers and buyers is made through Point of Sale (PoS) devices at retail shops. Beneficiaries are identified through documents such as Aadhaar, Kisan Credit Card or Voter ID. Subsidy is released to fertiliser companies on the basis of actual sales by retailers to beneficiaries.	Farmer identity and purchase data move through retailers and a government system. Your company sees part of it. Use what you see only for the scheme and supply work.	Department of Fertilizers
Integrated Fertilizer Management System (iFMS)	A pan-India digital platform developed by NIC for fertiliser DBT. It includes Aadhaar-based farmer authentication at PoS, captures transactions at manufacturing, import and retail points, and subsidy is released after a sale is recorded at the retailer level.	iFMS is the government's system. Company dashboards and exports drawn from it still need access control and logs on your side.	National Informatics Centre
Fertiliser (Control) Order, 1985	Dealers may sell only under an authorisation letter or certificate of registration (clauses 7 and 8). A retail dealer displays daily stock and prices (clause 4) and issues a cash or credit memo in Form M to the purchaser (clause 5). Records and returns in Form N are kept when the Controller directs (clause 35).	Dealer authorisation papers and sale memos are dealer and farmer records. Your dealer KYC files and any farmer details on memos need the same care as other personal data.	Government of Odisha (copy of the Order)
CERT-In Directions, 28 April 2022	Report specified cyber incidents to CERT-In within six hours of noticing them. Keep logs of ICT systems for a rolling 180 days within India. Sync clocks to NIC or NPL time servers, or servers traceable to them.	Applies to plants as well as head office. Keep this clock next to the DPDP breach steps in one plan.	CERT-In