The Digital Personal Data Protection Act 2023 (DPDPA) is set to redefine how organizations collect, process, and distribute personal data across India’s digital ecosystem. While most organizations believe that DPDPA compliance applies only to technology companies and large digital platforms, one of the most exposed and least understood domains is Talent Acquisition and Recruitment.
Every day, millions of candidates share sensitive personal and professional data with resume aggregators, recruitment platforms, and talent acquisition teams, assuming their information will be securely managed and used strictly for hiring purposes. In reality, candidate data often flows through multiple layers of data fiduciaries, processors, consultants, and third-party service providers, creating significant DPDPA compliance risks and accountability gaps.
The central challenge is not merely consenting collection, but end-to-end data accountability — including consent validity, data retention, right-to-forget, downstream data sharing, and responsibility for data misuse.
As DPDPA implementation phases approach (2025–2027), organizations involved in recruitment, HR consulting, and resume aggregation must reassess their data governance models, consent frameworks, and digital data distribution practices.
This article explores the hidden compliance risks in Talent Acquisition ecosystems and raises critical questions regarding Data Principal rights, Data Fiduciary responsibilities, and regulatory accountability under DPDPA.
Organizations that assume they fall outside the ambit of DPDPA compliance may face significant regulatory exposure soon.
Read detailed article: A Regulatory Perspective on Digital Personal Data Protection in Recruitment Ecosystems
