Data Fiduciaries must ensure personal data is accurate, complete, and up-to-date for its intended purpose.
Under DPDPA Section 8(3), Data Fiduciaries must make reasonable efforts to ensure that personal data processed is complete, accurate, and not misleading, having regard to the purpose for which it is processed. This is not an absolute obligation to guarantee perfection but a duty to take reasonable steps. When a Data Principal exercises the right to correction, the Fiduciary must update records promptly.
Inaccurate data can lead to incorrect decisions affecting customers — wrong credit scores, incorrect medical records, or mistaken identity flags. These errors can trigger complaints to the DPB and mandatory correction orders.
A Pune NBFC using outdated address data sends loan recovery notices to a customer's old address, causing them distress. The customer files a complaint with the DPB. The NBFC should have verified address accuracy before taking action based on personal data.
The accuracy obligation does not mean you must verify every data point independently. It means taking "reasonable efforts" — such as allowing easy correction and not using data you know to be outdated.
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