The Mandate of "Specified Purpose"
Under the Digital Personal Data Protection Act, 2023, processing personal data is only permissible for a lawful purpose for which the Data Principal has given consent or for certain legitimate uses.
A “Specified Purpose” is the fundamental anchor of every data interaction it is the explicit reason mentioned in the notice provided to the individual.
A purpose Register is no longer a luxury; it is the operational backbone required to track the “Intent” behind every byte of data you hold.
The Anatomy of Your Register
According to the DPDP Rules, 2025, your organizational register must be built on two pillars of clarity:
- Itemized Description: You must maintain a granular list of the specific personal data being processed.
- Specific Description of Services: For every purpose, you must link the exact goods, services, or uses enabled by that processing.
The Erasure Trigger: Purpose Completion
The sources mandate a strict “End of Life” for data. Personal data must be erased as soon as it is reasonable to assume that the specified purpose is no longer being served.
- The Default Rule: Processing must cease when the purpose is fulfilled.
- The Retention Exception: Data may only be kept beyond the purpose fulfillment if it is necessary for compliance with a law currently in force.
- The 48-Hour Warning: At least forty-eight hours before erasing data because a purpose has expired, you must inform the Data Principal, giving them a final opportunity to engage or exercise their rights.
The Significant Data Fiduciary (SDF) Requirement
For organizations notified as Significant Data Fiduciaries, a purpose register is a statutory prerequisite for the Data Protection Impact Assessment (DPIA).
- Audit Trail: The DPIA must include a comprehensive description of the rights of Data Principals and the purpose of processing their data.
- Risk Management: This register allows the independent data auditor to evaluate if your processing poses a risk to individual rights.
Strategic Insight: Avoiding the ₹250 Cr. Confession
In M&A and daily operations, a “Data Lake” where information swims without purpose limitation is a ₹250 crore confession. Without a Purpose Register, you cannot prove to the Data Protection Board that your security safeguards are “reasonable” or that your data retention is “lawful”.
The Purpose Register is the ‘Contract of Intent’ and it ensures that every piece of data you hold has a legal reason to exist in your systems.
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