DPDP for the Procurement 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)

Procurement buys gate systems, biometrics, canteen and agency services, often plant by plant.

Written for: Procurement 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

Data schedule in every plant-level contract.
Ask where data is hosted and who supports it.
Incident notice in hours.
Exit and deletion certificate.

A worked example

Procurement department

Buying a new biometric attendance system

Week 1Procurement asks where templates are stored and who supports the devices.
Week 2Templates stay on company servers in India.
Week 3Incident notice set in hours; deletion on exit in scope.
AfterExit certificate clause added.

Evidence kept

Questionnaire
Contract

Ask before you sign.

What others in the sector usually do. A DPDP question set added to the vendor onboarding form.

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 Procurement department asks, answered in full

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.

From your seat: Procurement department. Put the schedule into every new labour contract.

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

Dealer, retailer, mason and mechanic loyalty programmes: what do we need?

Short answer: Consent with a clear notice; collect only what rewards need

Loyalty schemes collect names, phone numbers, photos, ID and bank details to pay rewards. Joining is a choice, so this rests on consent with a clear notice. Collect only what rewards and tax rules need, keep bank details in one secure place, and make leaving the scheme easy. The loyalty vendor acts for you. Dealer KYC for appointment is a separate purpose from loyalty.

What the law says

Section 5 needs a notice. Section 6 sets what valid consent is, including easy withdrawal. Section 8(1) covers the loyalty vendor. Section 5 · Rule 3 · Section 6 · Section 8(1)–(2) · Section 8(5) · Rule 6 · Section 8(7) · Rule 8

Steps

List the fields the app and forms collect, and drop what rewards do not need.
Show a short notice at sign-up in the local language.
Keep bank details in the payout system only.
Add a data schedule to the loyalty vendor contract.
Close and delete inactive members' data on a set period.

Evidence to keep

Field list with reasons
Sign-up notice and consent records
Vendor schedule
Inactive member deletion log

Common mistakes

Bank details in spreadsheets sent by email
Field staff enrolling masons without telling them
Loyalty data reused for unrelated offers

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: Procurement department. Add the data-protection schedule to every purchase that involves personal data, and do not sign without it.

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

Can personal data be stored or accessed outside India?

Short answer: Yes, unless a sector rule says otherwise

Under DPDP, yes, unless the government restricts a country, and none had been restricted when this page was last reviewed. A sector rule can be stricter, for example RBI's rule that payment system data must be stored only in India. Remote support access from abroad also counts as data going outside India.

From your seat: Procurement department. Ask every vendor where data is hosted and where support staff sit.

Example in Manufacturing

Buyers' social audits, parent company HR systems and telematics platforms may hold data abroad.

What the law says

Section 16 allows transfers unless restricted, and keeps stricter sector laws in force. Rule 15 adds conditions on making data available to foreign states. Section 16 · Rule 15 · Section 8(1)–(2)

Steps

List where each system is hosted and where support teams log in from.
Check sector rules for localisation.
Put location and access terms in cloud and vendor contracts.
Keep the list current; new SaaS tools change it quietly.
Tell people in your notice if data goes abroad.

Evidence to keep

Hosting and access-location list
Contract clauses
Sector rule check

Common mistakes

Forgetting email, CRM and helpdesk SaaS
Ignoring overseas support logins
Assuming 'Indian vendor' means 'data in India'

Does deletion have to reach backups and test copies?

Short answer: Yes, through a written backup-expiry rule

Deletion should reach every copy you control. For backups, the usual practice is to let deleted records expire with the normal backup cycle, never restore them into live use, and write this down. Test and training copies should use masked data.

From your seat: Procurement department. Add an exit clause: data returned or deleted, with a certificate.

Example in Manufacturing

Gate and attendance servers at plants are often not backed up, or backed up for ever. Match backups to the schedule.

What the law says

Section 8(7) asks for erasure. Rule 6 asks for backups for continuity. The two meet in a backup retention rule that is short enough and written down. Section 8(7) · Rule 8 · Section 8(5) · Rule 6

Steps

List where copies live: backups, replicas, test, analytics, laptops, vendors.
Set backup retention to match the retention schedule.
Write a rule: deleted records are not restored into live systems.
Mask personal data in test and training copies.
Get deletion confirmations from vendors.

Evidence to keep

Backup retention settings
Written backup-expiry rule
Masking procedure for test data

Common mistakes

Ten-year backups for convenience
Live copies in test
Restoring old backups and bringing deleted records back

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: Procurement department. Vendor contracts need a short incident-notice time, in hours.

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

Does ISO 27001 or NIST CSF cover our DPDP duties?

Short answer: They cover security, not the whole Act

They help a great deal with the security part. ISO/IEC 27001 and NIST CSF 2.0 are good evidence of reasonable security safeguards. They do not cover notice, consent, rights, complaints or children's data. ISO/IEC 27701 adds privacy controls, but no certificate replaces the Act.

From your seat: Procurement department. Ask for current certificates and the latest audit summary, not just a logo on a slide.

Example in Manufacturing

ISO 27001 and plant safety audits give evidence for much of Rule 6.

What the law says

Section 8(5) and Rule 6 ask for reasonable security safeguards. A recognised standard is strong evidence of that duty, and only of that duty. Section 8(5) · Rule 6

Steps

Map your current controls to Rule 6.
Add the DPDP-only items: notice, consent, rights, complaints, children, retention.
Use the same evidence for audits and for DPDP.
Include privacy in the scope of your next internal audit.
Consider ISO/IEC 27701 if clients ask for it.

Evidence to keep

Control map
Audit reports
Gap list for DPDP-only items

Common mistakes

Treating a certificate as DPDP compliance
Scope that leaves out the systems with the most personal data
No owner for the non-security duties

Are we a Data Fiduciary or a Data Processor?

Short answer: Often both, for different data

You are a Data Fiduciary when you decide why and how personal data is used, as you do for your own staff and customers. You are a Data Processor when you handle data only on another organisation's instructions. Many organisations are both, for different data sets.

From your seat: Procurement department. Check whether the vendor will use the data for its own purposes. If yes, it is not just a processor.

Example in Manufacturing

Agencies act for you on worker data at your plant. In the fertiliser scheme flow, write down your role.

What the law says

Section 2(i) and 2(k) define the two roles. Section 8(1) puts the duties on the Data Fiduciary, which must use processors only under a valid contract. Section 8(1)–(2) · Section 17(1)(d)

Steps

List each data set you handle.
For each, ask: who decides the purpose?
Mark yourself as fiduciary or processor, and name the other party.
Check that contracts match the role.
Route requests about processor data to the fiduciary.

Evidence to keep

Role register by data set
Contracts matching the role

Common mistakes

Calling yourself a processor for data you use for your own purposes
No contract when you act as processor
Answering requests that belong to your client

The sections you will use most

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.
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(6) · Rule 7: Telling people about a breach. A leaked contractor list or a lost medical file is a breach. Tell affected people and the Data Protection Board without delay, and send the Board a detailed report within 72 hours. CERT-In's six-hour clock may apply too.
Section 16 · Rule 15: Data going outside India. Global buyers' social audits, overseas parent HR systems and telematics platforms may move data abroad. DPDP allows it unless a country is restricted; check contracts and support access.

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