Alumni Data Privacy under India’s DPDP Act, 2023: A Practical Guide for Institutions

What is the DPDP Act and does it apply to alumni data?

The Digital Personal Data Protection Act, 2023 is India’s law on the processing of digital personal data. It applies to personal data collected in digital form, and to data collected offline and later digitised. An alumni database, a reunion registration form, a donor list or a mentoring sign-up sheet all contain personal data, so the Act is relevant to schools, colleges, universities and alumni associations alike.

The Ministry of Electronics and Information Technology (MeitY) notified the Digital Personal Data Protection Rules in 2025, with different obligations coming into force in phases. Timelines and details matter here, so read the Act and Rules on MeitY’s website and confirm which provisions are in force when you read this.

Official sources: Digital Personal Data Protection Act, 2023 (MeitY)

Related: MeitY — Digital Personal Data Protection Act, 2023 and Rules

Key DPDP terms in an alumni context

The Act uses a few defined roles. Mapping them to your alumni programme makes responsibilities clearer.

What does consent and notice look like for alumni?

Where consent is the basis for processing, the Act expects it to be free, specific, informed, unconditional and unambiguous, given through a clear affirmative action, and as easy to withdraw as to give. It should be accompanied by a notice that explains, in clear language, what personal data you collect, why, how alumni can exercise their rights and how to complain to the Board. The Act also allows certain specified legitimate uses without consent; whether one applies is a legal question for your adviser.

For an alumni portal, this usually means a registration step where the alumnus sees a short notice and actively agrees, separate choices for things like directory visibility and marketing messages, and a settings page where they can change their mind.

• Do not pre-tick consent boxes.
• Separate essential processing from optional uses such as directory listing or fundraising appeals.
• Keep a record of when and how each person consented.
• Offer the notice in English and, where the Act or Rules require or it helps your community, in other languages from the Eighth Schedule.

What rights do alumni have?

Data principals have rights to obtain information about the processing of their data, to correction, completion, updating and erasure, to grievance redressal, and to nominate another person to exercise their rights in case of death or incapacity. Practically, give alumni a self-service profile where they can update details and privacy settings, publish a contact for privacy requests, and have a documented process for responding within the time the Rules prescribe.

What about current students and children?

Alumni are adults, but alumni programmes often involve current students, for example mentoring, career talks or scholarships. For anyone under 18, the Act requires verifiable consent of a parent or lawful guardian and restricts tracking, behavioural monitoring and targeted advertising directed at children, subject to exemptions in the Rules. Schools should route student participation through parent consent processes they already run, and keep student data out of alumni-facing directories.

Related: Safeguarding in alumni mentorship programmes

Security, vendors and breaches

A data fiduciary must take reasonable security safeguards to prevent personal data breaches, and must ensure processors such as software vendors act under a contract. In the event of a personal data breach, the Act requires intimation to the Data Protection Board and to affected data principals in the manner prescribed. Review your vendors’ security documentation, limit admin access, use role-based permissions and keep an audit trail.

• Limit who can export the full alumni list.
• Remove access for committee members when their term ends.
• Avoid circulating alumni spreadsheets over WhatsApp or personal email.
• Delete verification documents once verification is complete.
• Define retention: delete or anonymise data you no longer need.

A practical DPDP checklist for alumni offices

Use this list as a starting point for a conversation with your legal adviser, not as a compliance certificate.

• Map what alumni data you hold, where, and why.
• Publish a clear privacy notice for alumni.
• Collect granular consent with an easy way to withdraw.
• Provide self-service correction and a contact for requests and grievances.
• Sign data processing terms with your platform and messaging vendors.
• Set up breach response steps and responsibilities.
• Train staff and volunteers who handle alumni data.

Related: Connect My Alumni and the DPDP Act · Build an alumni database from scratch

How Connect My Alumni helps

Connect My Alumni provides self-managed alumni profiles with privacy controls, per-category notification preferences, verification workflows, role-based admin access and an activity audit trail. These features support your DPDP processes but do not make an institution compliant on their own; policies, notices and decisions remain the institution’s responsibility.

Official sources: Digital Personal Data Protection Act, 2023 (MeitY)

Related: Activity audit trail · Connect My Alumni vs Almabase · Pricing

Important: this is not legal advice

This guide summarises the DPDP Act in general terms for alumni programmes. It is not legal advice. The Act, the Rules and their phased commencement dates should be read in full on MeitY’s website, and you should consult a qualified lawyer about your specific situation. Verify with the official source before acting.

Official sources: Digital Personal Data Protection Act, 2023 (MeitY)