Excerpt from The Hindu BusinessLine Article, Published on November 25, 2025
The newly notified Digital Personal Data Protection Rules 2025 (DPDP Rules) impose sweeping obligations on companies handling personal data. This includes a mandate for erasing personal data in many contexts — a requirement that carries serious implications for developers of Large Language Models (LLM).
India’s data privacy law — the Digital Personal Data Protection Act 2023 (DPDP Act) — is now backed by detailed operational rules. Under these rules, data fiduciaries must obtain explicit, informed consent, deploy strong security safeguards (like encryption or tokenisation), and respect data minimisation, retention and erasure requirements.
For AI firms and LLM developers, this marks a major shift. If personal data is used to train or fine – tune models, companies must ensure that data is processed lawfully — with consent — and must also support “unlearning” or erasure when consent is withdrawn or when user data is no longer required.
Key changes impose consent-driven data use, mandatory deletion if the user becomes inactive or revokes consent, and stricter data handling, logging, and security standards for any processing — including for training AI.
For developers building LLMs or AI – powered services in India, compliance will likely require re-engineering data pipelines — anonymising or pseudonymising data, adding consent – management layers, incorporating “unlearning” mechanisms, and auditing data provenance for training records. Experts quoted in recent coverage said the DPDP Rules “sharply raise the compliance bar” for AI firms, especially those relying on personal data for model training.
As a result, companies deploying LLM – based solutions must treat privacy not as an afterthought — but as a primary design principle. This could involve using privacy – preserving techniques, maintaining robust consent and deletion workflows, and building transparent, auditable processes for any data — human or synthetic — used in AI training.
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