Quick Answer
Payment aggregators and payment gateways process financial personal data of millions of Indian consumers and are subject to both RBI PPI guidelines and the DPDP Act 2023. Processing payment data requires explicit consent for purposes beyond transaction completion, and tokenisation requirements reduce retention of card data. Payment aggregators are likely SDF candidates given the volume and sensitivity of data processed.
Quick AnswerPayment aggregators must implement purpose limitation for transaction data, restrict merchant data sharing, align DPDP consent with RBI regulations, and implement rigorous breach notification procedures.
DPDP Compliance Checklist
- Align DPDP compliance with RBI PA/PG guidelines and PCI-DSS requirements — satisfy all three
- Map all data flows: payer, merchant, bank, sub-aggregator, fraud analytics
- Implement purpose limitation — payment data cannot be used for marketing without explicit consent
- Restrict transaction analytics sharing with third parties — obtain consent for data monetisation
- Implement 72-hour breach notification SOP — payment breaches are highest priority
- Review merchant onboarding data sharing agreements — add DPDP DPA clauses
- Implement tokenisation for payment data — reduce personal data footprint
- Restrict refund data use — do not use refund patterns for credit scoring without consent
- Train fraud analytics and compliance teams on DPDP data minimisation
- Conduct quarterly DPDP and PCI-DSS joint compliance review
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Frequently Asked Questions
Can payment aggregators use transaction data for credit scoring?+
Only with explicit payer consent for this purpose. Transaction data collected for payment processing cannot be repurposed for credit scoring without separate consent.
How does DPDP interact with RBI PA/PG regulations?+
They complement each other. RBI regulations govern the payment infrastructure; DPDP governs personal data processing within that infrastructure. Both must be satisfied simultaneously.
What is the penalty exposure for a payment data breach under DPDP?+
Payment data breaches affecting large volumes of individuals can attract maximum penalties — up to ₹250 crore. PCI-DSS fines from card networks add additional exposure.
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