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DPDP readiness

How KaapiPass maps to the Digital Personal Data Protection Act, 2023 and the DPDP Rules, 2025. This is our engineering view, not legal advice or a claim of compliance.
RequirementHow KaapiPass handles itStill needs
Notice before consent (s.5, Rule 3)An itemised notice in English, Hindi and Kannada sits on the join page, above the consent boxes. It covers the data, the purpose, withdrawal, rights and how to complain.Lawyer + native-speaker review
Free, specific, unambiguous consent (s.6)Separate unticked boxes: one for the loyalty card (required) and one for offers (optional). Joining is blocked unless the card consent is ticked.Lawyer review of wording
Withdrawal as easy as giving (s.6(4))One tap on the card's “My data” page switches off offers or deletes the card. Every change is logged.None
Consent recordsEach grant, withdrawal and erasure is logged with a timestamp, the notice version and the channel.None
Purpose and data limitationOnly name and mobile number are collected, plus visit records needed for the stamp card.None
Rights: access, correction, erasure (s.11–13)Self-serve on the card: view, download as JSON, correct the name, delete one card or everything.Process for requests by other channels
Grievance redressal (s.13)Grievance officer section on the Trust page.Officer name and contact: TO BE FILLED
Retention and erasure (s.8(7), Rule 8)Inactive cards are purged automatically (365 days by default, configurable per cafe). A purge job is included.Confirm retention period and pre-erasure notice
Security safeguards (s.8(5), Rule 6)Phone numbers encrypted at rest, hashed passwords, role separation, audit log, security headers.Independent security review
Breach notification (s.8(6), Rule 7)A written breach response procedure (docs/BREACH-RESPONSE.md) with timelines for informing the cafe, affected people and the Board.Lawyer review
Children (s.9)Members must declare they are 18 or older; the declaration is logged. No under-18 sign-ups are knowingly accepted.Lawyer review of the age-declaration approach
Fiduciary / processor rolesThe cafe is the Data Fiduciary; KaapiPass is the Data Processor and acts on the cafe's instructions. See the DPA template.Lawyer to finalise DPA
Data locationThe deployment's data region is shown on the Trust page. Production must be hosted in India.Hosting decision
No selling, no trackingNo ad or analytics cookies. Fonts are self-hosted. Member data is never sold or shared for marketing.None

Section references are indicative and must be checked by a lawyer. Timeline as we read it (not verified by a lawyer): the DPDP Rules, 2025 were notified on 13 November 2025 (announced 14 November), and most Data Fiduciary obligations start 18 months later, around 13 May 2027. In January 2026 MeitY consulted on shortening this to 12 months (13 November 2026); we have not seen a final amendment, so we are building as if the earlier date applies. Reviewed internally on 31 October 2026.