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Q1 - How does DPDPA apply to employee data?

Answer
  • Employee data is personal data, so it falls under DPDPA.
  • Employers can process employee data without consent if it is necessary for employment purposes (salary processing, compliance with labour laws, tax deduction, workplace safety).
  • But for anything beyond necessity, consent is required.
Example
  • ABC Manufacturing Ltd. can process Narayan’s Aadhaar and PAN for PF contributions (necessary).
  • But if ABC wants to use his personal photo for marketing campaigns, it must seek his consent.