Clear notice & consent
Itemised notice in plain language; consent that can be withdrawn as easily as given.
India's Digital Personal Data Protection Act puts consent at the centre. For regulated onboarding, RBI's video-KYC framework also expects liveness and face matching.
Processing needs free, specific, informed and unambiguous consent with a clear notice, or another legitimate use. Data fiduciaries must secure data and erase it when the purpose ends.
Notified in November 2025 with phased commencement for most obligations — check current dates with counsel.
RBI's KYC Master Direction permits video-based customer identification with liveness checks and face matching against documents.
Classed biometrics as sensitive personal data; being superseded as DPDP obligations commence.
Itemised notice in plain language; consent that can be withdrawn as easily as given.
Use face data only for the stated purpose, e.g. onboarding.
Delete templates when the purpose is met or consent is withdrawn.
Use UIDAI's authorised channels for Aadhaar face authentication; SIMSIM complements selfie-to-document matching and liveness.
Less sensitive data held, smaller breach impact.
Honour withdrawal and retention schedules in code.
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General information, not legal advice. Last reviewed 2026-09-30. Confirm requirements with qualified counsel.
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