DPDP Act Challenge in Recruitment and Hiring

The Digital Personal Data Protection Act, 2023 (DPDP Act) marks a significant milestone in India’s regulatory landscape, establishing a formal legal framework governing how personal data is collected, used, stored, shared and deleted by organisations. With the DPDP Rules, 2025 officially notified on 14 November 2025, obligations around consent, data minimisation, retention policies and breach reporting are now actionable and enforceable. Yet, despite the clarity offered by the rules, many teams across HR, recruitment and background verification (BGV) functions remain uncertain about practical implementation and compliance readiness.

Key pain points that HR, recruitment and BGV functions are grappling with include:

• Consent complexity: Broad, “one-size-fits-all” consent forms do not meet the law’s requirement for clear, purpose-linked consent that can be withdrawn at any time.
• Data minimisation and retention: Holding all candidate data “just in case” is no longer compliant. Organisations must determine what data is essential for the hiring process and set retention and deletion policies accordingly.
• Vendor and third-party risk: Sharing candidate personal data with BGV vendors or external platforms without robust contractual clauses on DPDP compliance exposes the company to liability.
• Secure handling and breach preparedness: Companies must secure candidate data at rest and in transit, monitor for breaches and have reporting mechanisms ready—functions that many traditional HR systems do not natively support.
• These operational realities are not simply administrative matters; they have material legal and financial implications. Non-compliance exposes organisations to significant penalties and reputational risk.

Given this backdrop, organisations using standalone spreadsheets, generic HR information systems or fragmented tools often find themselves playing catch-up—mapping workflows retroactively rather than embedding compliance into the process.

Zoho Recruit is positioned to address the core DPDP compliance challenges facing hiring and talent acquisition teams by embedding privacy-centric data governance capabilities directly into recruiting workflows. Below are the ways Zoho Recruit can help:

Zoho Recruit can be configured to:

• Present purpose-specific consent flows to candidates during data collection (for resumes, ID proofs or background checks), replacing generic consent with clear, actionable approvals.
• Maintain an audit trail of consent records, allowing HR and compliance teams to demonstrate when and how consent was obtained, modified or withdrawn.

This functionality aligns directly with the DPDP requirement for explicit, revocable consent, and continuous evidence of compliance.

Rather than indiscriminately collecting all possible candidate information, Zoho Recruit helps teams:

• Define structured data fields that capture only essential candidate data relevant to specific recruiting processes.
• Eliminate redundant or optional data collection points based on configurable templates.

By limiting data intake to predefined, legally defensible purposes, organisations reduce unnecessary exposure to personal data risks and align with the DPDP emphasis on minimisation.

A crucial DPDP requirement is defining how long data is held and when it must be deleted. Zoho Recruit enables:

• Configurable retention policies so candidate records automatically transition to archival or deletion states after a defined period, based on business and legal needs.
• Automated data purging workflows that respect retention rules, reducing the manual burden on HR teams and closing compliance gaps.

This ensures adherence to the DPDP’s mandate for time-bound data retention and deletion.

Zoho Recruit offers:

• Role-based access controls to ensure that sensitive candidate data is visible only to authorised stakeholders.
• Encryption at rest and in transit, aligning with best practices for data security.
• Logging and monitoring capabilities to support internal audits and breach investigation processes.

Collectively, these features support DPDP’s requirements for secure storage and handling of personal data.

Many organisations outsource parts of their hiring or verification process (e.g., background checks). Using Zoho Recruit helps in two ways:

• Centralised vendor data flows are tracked and controlled within the system, reducing unmonitored data transfers.
• Agreements and data processing records can be associated with vendor profiles, allowing HR teams to enforce compliance clauses and monitor obligations.

This assists with contractual risk management—a DPDP expectation that organisations maintain control and oversight over data shared with third parties.

Compliance with the DPDP Act doesn’t need to be a parallel project disconnected from daily hiring workflows. In fact, organisations that integrate privacy and compliance into their talent acquisition tech platforms stand to gain operational discipline, reduced legal risk and improved candidate trust. Common candidate questions such as “Why do you need this data?” or “How long will you keep it?” become opportunities to reinforce transparent, trust-based employer brand experiences.

The DPDP Act fundamentally reshapes how Indian organisations must think about personal data in hiring and recruitment. Rather than treat compliance as a burden or a checkbox exercise, forward-looking companies are investing in systems that build privacy by design into recruitment operations. Zoho Recruit offers a coherent, configurable platform that enables HR teams to meet DPDP requirements while maintaining operational productivity.

In doing so, organisations not only mitigate legal and financial risks but also strengthen trust with candidates and employees—a strategic advantage in today’s competitive talent marketplace.