Core Concepts

Processing of Personal Data

Defined in §2(x), DPDPA 2023

Any operation performed on digital personal data including collection, storage, use, sharing, or erasure.

What does “Processing of Personal Data” mean?

Processing means any wholly or partly automated operation performed on digital personal data. This includes collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, alignment, combination, restriction, erasure, or destruction. Under DPDPA, virtually anything you do with personal data constitutes processing and requires a lawful basis.

Why does this matter for your business?

Every interaction with personal data — from reading it in a dashboard to storing it in a backup — is "processing" under DPDPA. This broad definition means compliance obligations apply to your entire data lifecycle.

Real example

When a Noida SaaS company collects user signups, stores them in PostgreSQL, analyses usage patterns, shares anonymised metrics with investors, and eventually deletes inactive accounts — each of these steps is a separate processing activity requiring documentation in the RoPA.

Common misconception

Many believe "processing" only means active computation or analysis. Simply storing data in a backup, even if never accessed, constitutes processing under DPDPA.

Related terms

DPDPA Shield automates Data Inventory & RoPA. See how →