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Quick Answer

AI and ML companies face acute DPDP Act 2023 exposure because models are trained on large datasets that often contain personal data. Under the Act, using personal data to train or fine-tune models needs a lawful basis (usually consent or a recognised legitimate use), purpose limitation applies, and scraping personal data from the web is high-risk. This guide and checker help AI/ML teams in India size and reduce their data-protection risk.

DPDP for AI & ML Companies

Training data, web scraping, consent and model risk — how India's DPDP Act 2023 applies to AI and ML teams.

What's your AI training-data risk?

DPDP checklist for AI/ML teams

Why AI companies are a DPDP priority

Generative and predictive models are only as good as their training data, and that data frequently includes personal information — user content, support transcripts, scraped text, purchased datasets. The DPDP Act 2023 does not exempt AI: if personal data of individuals in India is processed, the Act's consent, purpose-limitation, security and rights obligations all apply.

The hardest issues are lawful basis for training, provenance of scraped or purchased data, and honouring erasure once data is baked into a model. Teams that design for these from the start avoid expensive retraining and regulatory risk later.

Get the AI/ML DPDP playbook (free)

Lawful-basis guidance for training data, a dataset provenance template, and a model DPIA starter.

Frequently Asked Questions

Can we train models on customer data we already collected?+
Only if your lawful basis and the original purpose cover it. Reusing data collected for one purpose to train models is a purpose-limitation issue under the DPDP Act — you may need fresh consent or a recognised legitimate use.
Is web scraping legal under the DPDP Act?+
Scraping personal data is high-risk: the individuals have not consented to your processing. Even publicly available data is not a free pass under the DPDP framework. Assess carefully and prefer licensed or consented sources.
How do we handle erasure requests for trained models?+
Maintain the link between source records and your pipeline so you can remove data and, where feasible, retrain or apply mitigations. Document your approach as part of your DPDP accountability.

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