With the Digital Personal Data Protection (DPDP) Act coming into force, responsibility of the resident data is now on the Resident Welfare Associations (RWAs)/Management Committees.
According to the Act, there are substantial penalties (upto 250 Crores) for non-compliance.
To help associations understand what the law means in practice, ADDA conducted an exclusive DPDP awareness workshop for Management Committee members.
The session was presented by San Banerjee, CEO & Co-Founder of ADDA, and focused on explaining:
- What the DPDP Act is
- How it directly impacts RWAs
- Practical steps societies must take to stay compliant
This blog captures what was covered in the workshop, the key insights from the presentation, and important questions raised by MC members.
Table of Contents
What Is the DPDP Act?
The Digital Personal Data Protection Act is a central government legislation that governs how digital personal data of Indian citizens can be collected, processed, stored, and used.
At its core, the DPDP Act is built on two principles:
- Personal data must be used only for the lawful purpose for which it is collected
- Need for Explicit Consent, and Purpose Limitation
Before DPDP, residents had limited legal options if their data was misused. With DPDP, clear accountability, penalties, and grievance mechanisms now exist.
Why DPDP Is Critical for RWAs and Management Committees
A key message from the workshop was simple but serious:
Under DPDP, the RWA, is recognised as Data Fiduciary, not the Community App, and is hence legally accountable for resident data.
RWAs routinely collect and process sensitive digital personal data such as:
- Owner and tenant details
- Phone numbers and email IDs
- Vehicle information
- Visitor entry logs
- Domestic staff data
- ID proofs and documents
Since RWAs decide which software to use, they are considered the Data Fiduciary under the law. If resident data collected and uploaded to a third party platform, is misused by the third party platform, the RWA is answerable.
Penalties under DPDP can go up to ₹250 crore, making awareness and compliance non-negotiable.
What Was Covered in the Workshop
The session was designed to help Management Committee members understand why DPDP matters to RWAs and how it changes accountability in day-to-day operations. The discussion focused on real situations faced by housing societies, explained through practical governance lenses.
1. Life Before DPDP
The workshop began by reflecting on common data privacy issues faced by residents and RWAs before DPDP, and why complaints often went unresolved.
2. What Changes After DPDP
San explained how DPDP fundamentally alters the legal landscape — introducing resident rights, penalties, and clearly defined accountability for data handling.
3. Key Roles Defined Under the Act
The session clarified how DPDP defines responsibilities across different stakeholders involved in collecting resident data and processing it, and how the responsibility to ensure that this data is used for lawful purposes only, shifts to the Management Committee.
4. How RWAs Typically Use Resident Data
Different types of data usage by RWAs were broadly classified to help committees understand the compliance expectations around such data use.
5. Governance Risks Around Advertisements
The discussion highlighted why mixing official communication with promotions can create trust and compliance challenges under DPDP.
Several practical scenarios, decision frameworks, and implementation considerations were discussed live during the workshop.
Key Questions from the Q&A Session
Below are some of the most common questions raised by Management Committee members during and after the workshop. Here we have listed the questions and the responses, for reference of management committee members and interested residents.
1. Before DPDP, residents were not taking legal action. Why would they take it now?
Before DPDP, residents had no clear legal framework to pursue misuse of digital personal data. While consumer courts existed, there was no specific law addressing data protection. DPDP changes this by explicitly granting citizens legal rights and a structured grievance mechanism, making enforcement practical and actionable.
2. Is it advisable for RWAs to completely avoid external or promotional use of official apps?
The workshop advised RWAs to first clearly identify their official platform, which residents are mandated to use. On such platforms, mixing official communication with promotions increases compliance and trust risks. If external use is considered, it must be carefully governed and consent-driven.
3. Some apps allow residents to pay to remove ads. Is that compliant under DPDP?
Consent under DPDP must be symmetrical. If a resident can give consent easily, they must also be able to withdraw it just as easily. Making residents pay to withdraw consent is not aligned with DPDP principles.
4. Are digital display boards or lift lobby screens showing ads a DPDP issue?
No. Digital display boards do not involve processing of residents’ digital personal data. Since no personal data is being captured or used, DPDP does not apply to such offline or display-only advertising.
5. How should RWAs handle consent for visitors?
RWAs should ensure visitors are informed about what data is collected, why it is collected, and how long it is retained. Need for clear communication at entry points was discussed.
6. Is consent required for raising maintenance bills or storing family member data?
No. Activities such as billing, receipts, official communication, and basic household data fall under lawful use. These are essential functions of an RWA and do not require explicit consent under DPDP.
7. Does sharing outstanding dues (name and amount only) on official WhatsApp groups violate DPDP?
No. Recovering dues is a lawful function of an RWA. However, care should be taken to limit shared information strictly to what is necessary and avoid sharing sensitive personal details.
8. Residents prefer WhatsApp communication. Does DPDP restrict this?
DPDP focuses on the purpose of data usage and explicit consent. Official announcements related to safety, utilities, or emergencies may be shared across channels to ensure awareness. Typically WhatsApp groups are not recognised as an official channel for communication, and residents have the choice to leave anytime. If that is the case, WhatsApp can be used for promotions. Residents basically can’t be forced to see Ads.
RWAs should, however, clearly define which platform is considered official for governance purposes.
9. Does DPDP apply to manual visitor registers?
DPDP applies only to digital personal data. Manual registers are outside its scope. However, once that data is digitised (for example, entered into software or spreadsheets), DPDP becomes applicable.
10. If a resident does not give consent, will promotional announcements be blocked for them?
Yes, this is the intended design discussed. External or commercial communication should only reach residents who have explicitly consented. The exact mechanisms were discussed as part of future platform enhancements.
11. Does a Data Protection Officer (DPO) need government certification?
No certification is required. The role is about awareness, oversight, and accountability. Participation in DPDP awareness workshops itself contributes to demonstrating organisational intent and preparedness.
12. Should Aadhaar or PAN be collected and stored by RWAs?
The workshop strongly advised avoiding storage of government IDs wherever possible. IDs may be used for verification purposes, but long-term storage significantly increases risk due to the sensitivity of such data.
13. How should RWAs handle biometrics used for entry or facility access?
If biometric data is stored or processed by a third-party device or vendor, that vendor becomes a data processor. RWAs must ensure appropriate contractual safeguards and DPDP alignment with such vendors.
14. Are RWAs or software providers subject to audits under DPDP?
There is no provision for random audits as of now. Audits may occur if a formal grievance is escalated to the Data Protection Board. This reinforces the importance of documentation and responsible data practices.
15. Is AGM approval enough to adopt software, or is individual consent required?
For lawful RWA functions, AGM approval is sufficient. DPDP does not mandate individual consent for choosing software, as long as data usage remains within lawful purposes.
16. Are RWAs required to take consent for all activities conducted by the Management Committee?
Consent is required only when residents’ digital personal data is used beyond essential association functions. Activities not involving personal data fall outside DPDP’s scope.
17. How can RWAs prevent misuse of resident data by society staff?
Training and sensitisation are critical. Staff must understand that casual sharing or misuse of resident data carries serious legal and financial consequences under DPDP.
18. What if DPDP compliance is still a work in progress?
DPDP recognises phased adoption. Demonstrating intent, choosing compliant platforms, and participating in awareness initiatives significantly reduces risk during the transition period.
Why This workshop Was Important
This session marked an important shift:
- Data privacy is no longer optional
- RWAs are now custodians of resident trust
- Early awareness reduces future legal risk
Participants will also receive:
- Attendance certificates as proof of DPDP awareness
- Follow-up FAQs and resources
Closing Note
DPDP is to India what GDPR was to Europe — a fundamental shift in how personal data is collected, processed, and protected.
By attending this workshop, Management Committees took an early and responsible step toward safeguarding resident data, building long-term trust, and future-proofing their associations against regulatory risks.
To support more RWAs and society staff in this transition, additional DPDP awareness workshops are being conducted with limited seats, allowing for deeper discussion and practical guidance.
If you would like to attend an upcoming session, you can check details and register here:
👉 https://go.adda.io/dpdprwaworkshop