DPDP Act compliance

DPDP Act compliance for hr, staffing and recruitment firms: what changes by May 2027

Staffing and recruitment agencies, payroll processors, HR-tech and background verification firms handle CVs, ID proofs, salary data, bank details, background checks and attendance. Here is what the DPDP Act means for you and what to fix first.

189 days to the DPDPA compliance deadline (13 May 2027)See the 2027 roadmap →
Quick answer

HR, staffing and recruitment firms process large volumes of candidates' and employees' personal data and must comply with the DPDP Act by 13 May 2027. Employers can process employee data for employment purposes without consent, but candidate databases, CVs from job portals and background checks need a lawful ground and a notice. Staffing firms must work out, contract by contract, whether they act as a Data Fiduciary or a Data Processor for their clients.

Deadline
13 May 2027
Employee data
Legitimate use (s.7(i))
Candidate CV databases
Need notice and retention limits
Client contracts
Fiduciary or processor?

Where hr, staffing and recruitment firms face the most DPDP risk

DPDP risk areas for hr, staffing and recruitment firms
AreaWhat to do
CV databases and job-portal downloadsNotice to candidates; delete stale CVs on a schedule
Background verificationTell the candidate, limit checks to the role, contract with the BGV vendor
Payroll for clientsAct as processor under a written contract with security and breach terms
Sharing CVs with multiple clientsCandidate's agreement before submitting to each client
ID documents (Aadhaar, PAN)Mask Aadhaar numbers, restrict access, encrypt storage

Other rules that apply alongside the DPDP Act

  • Aadhaar Act rules on storing and masking Aadhaar numbers
  • Labour and tax laws on keeping employee records

Where another law sets a stricter or longer requirement, follow both: the DPDP Act does not override sector rules on retention or storage.

Six steps to comply

  1. Map candidate and employee data flows, including job portals and client handovers.
  2. Decide your role (fiduciary or processor) for each client service and update contracts.
  3. Add a candidate privacy notice and a CV retention period.
  4. Secure ID documents and bank details; mask Aadhaar.
  5. Prepare a breach plan, since staffing databases are a frequent target.
  6. Train recruiters on consent before sharing CVs.

Most DPDPA duties apply from 13 May 2027, with penalties up to ₹250 crore per breach. See the DPDPA 2027 roadmap and the DPDP compliance checklist.

Want it done for you? Our DPDP compliance service covers data mapping, notices, consent, vendor contracts, breach plans and staff training for staffing agencies, recruitment firms, payroll and HR-tech providers.

Frequently asked questions

Is a staffing agency a Data Fiduciary or a Data Processor under DPDP?

It depends on the service. For its own candidate database it is a Data Fiduciary. When it runs payroll or onboarding on a client's instructions, it is usually the client's Data Processor and needs a contract.

How long can recruiters keep CVs under the DPDP Act?

Only as long as needed for the purpose the candidate gave it for. Set a retention period, for example 12 to 24 months, and delete or re-confirm after that.

DPDP guides for other industries

See all deadlines on the compliance calendar, or browse the compliance hub.

This guide is general information based on the law as of 25 October 2026, not legal advice. Rules and dates can change by notification; speak to a professional about your situation.

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