Automating State Data Processing Compliance: Operationalising Section 7(b) read with Rules 3 and 6

1. Introduction  

As governments depend more on digital tools to provide subsidies, benefits, licenses, and public services, the amount and sensitivity of personal data being handled by the government and its agencies have grown a lot. Now, delivering welfare, issuing digital certificates, and offering services that require permission all rely on sharing large amounts of data between different departments and databases. In response to this, the Digital Personal Data Protection Act, 2023 (DPDPA) has introduced a balanced framework that lets the government process personal data for certain public tasks, while also ensuring that there are protections for accountability, transparency, and security. 

Section 7(b) of the DPDPA allows the government to use personal data as a "legitimate purpose" when providing specific subsidies, benefits, services, certificates, licenses, or permits, but only under certain conditions. However, this exception does not mean the government can ignore its compliance responsibilities. When we combine it with Rule 3, which states notice requirements, and Rule 6, which sets standards for reasonable security, it's clear that government data processing must still be well-managed, secure, and open. This blog explores how these rules can be effectively implemented through automation to ensure lawful, scalable, and justifiable compliance in government-led data processing. 

2. Understanding Section 7(b) 

Section 7 of the Digital Personal Data Protection Act, 2023, lists "certain legitimate uses" where personal data can be processed without needing fresh consent. Clause (b) specifically allows the State and its agencies to use personal data for providing subsidies, benefits, services, certificates, licenses, or permits, but only under certain conditions. This provision reflects a real-world situation where many public services rely on ongoing data use, and asking for consent at every step would be too cumbersome to manage. 

However, Section 7(b) is not a blanket exemption. It only allows data processing if one of two conditions is met. 

• First, the individual must have already given consent for their data to be used by the State or its agencies for a similar public purpose. 

  
  

• Second, the data must already be part of a State-run database, register, or document that the Central Government has officially notified. 

  
  

In both cases, the data processing must follow the rules set out in relevant government policies or laws about personal data. From a compliance viewpoint, this creates a limited and specific legal basis for data use. The State is allowed to reuse data for public services, but only within clearly defined limits. Any attempt to go beyond these limits would not be protected under Section 7(b). This highlights the importance of following proper procedures and maintaining strict operational controls. 

3. The Operational Challenge of State Data Processing 

State data processing usually happens on a large scale. It involves many departments, agencies, and old systems. Data is often gathered once and used repeatedly for tasks like checking eligibility, giving out benefits, verifying information, or issuing certificates. While Section 7(b) allows this reuse, it also puts more pressure on proper governance. 

• One major challenge is keeping track of the purpose of data use. State organisations need to show that every time data is processed, it's directly tied to providing a specific benefit, subsidy, or service. If the purpose isn't clear, reusing data could lead to unauthorised use. 

  
  

• Another issue is knowing where the data comes from and its history. When using clause (ii) of Section 7(b), the state has to make sure the data is from an official database or register and was properly converted into digital form. In real life, many government systems pull data from different sources, which makes it hard to confirm where it came from. 

  
  

• Lastly, the large amount of data being processed increases security risks. With data spread across departments and shared with outside partners, any security breach could have serious consequences. That's why Rules 3 and 6 are so important in putting Section 7(b) into action. 

  
  

4. Rule 3: Notice Obligations Do Not Disappear for the State 

A common misunderstanding is that using data under Section 7(b) means you don’t have to follow transparency rules. Rule 3 of the DPDP Rules, 2025, clearly says this isn’t true. Even when data is processed without new consent, the Data Fiduciary, whether it’s a private company or the government, must give the Data Principal a clear and separate notice. 

This notice should be easy to understand on its own, not hidden in other information. 
It needs to explain in simple terms what personal data is being used and for which specific public purpose. Rule 3 also requires the notice to include ways for people to withdraw consent (if possible), exercise their rights under the Act, and file complaints with the Data Protection Board. For government bodies, this means that platforms used for public services must be designed with user rights in mind, not just for making things easier for the administration. 

In practice, Rule 3 requires state organisations to create consistent notices across different departments while making sure they are relevant to each specific service. Therefore, automation is very crucial in this regard. Trying to manage accurate, service-specific notices manually across many platforms is not practical at a large scale. 

5. Rule 6: Security Safeguards as a Non-Negotiable Baseline 

Rule 6 sets out the basic security measures that all Data Fiduciaries, including the State and its related bodies, must follow. If we look into it technically, Rule 6 includes steps like encrypting, hiding, confusing, or replacing personal data to protect it. For State systems that handle sensitive personal information, security must extend beyond network boundaries and focus directly on protecting the data itself. 

Access control is also a key part of this rule. It requires proper ways to make sure only people or systems that are allowed can access personal data. In the State environment, where access is often wide open and roles are not clearly defined, this is a major change. Another important aspect is keeping track of what’s happening. Rule 6 requires keeping records, monitoring activity, and reviewing these to spot unauthorised access, look into any incidents, and stop them from happening again. These records must be kept for at least a year to help find breaches and keep things running smoothly. 

Importantly, Rule 6 also applies to any third-party companies that work for the State. 
Any contracts with these vendors must include clear and enforceable security terms. This means managing these vendors' security is also a key part of compliance. 

6. Why Automation Is Essential for Section 7(b) Compliance 

   
   

   State data processing under Section 7(b) happens on a large scale and involves many complex elements, including multiple departments, old systems, and outside service providers. When combined with Rules 3 and 6 from the DPDP Rules, 2025, the need to follow these rules becomes ongoing, timely, and dependent on the systems in place. Trying to follow these rules manually is not enough, as the structure of the rules doesn’t support it. Automation is necessary to make sure data is used only for its intended purposes, is clear, safe, and can be shown to work properly. 

   
   

• State data processing happens at a large scale and quickly. Manual ways of ensuring compliance can't keep up with the amount of data, how fast it moves, and how it's shared between different departments. Section 7(b), along with Rules 3 and 6, requires constant and timely compliance that needs to be enforced in real time. 

  
  

• Data must be used only for approved public purposes like subsidies, benefits, or certificates. Automation helps link data access and use directly to these approved uses. It makes sure that data isn’t used for anything else that isn’t allowed under Section 7(b). 

  
  

• The requirement for transparency means notices must be generated and updated as services and platforms change. Static disclosures can't reliably meet the notice requirements of Rule 3. Automated systems make it easier to create, update, and send out these notices consistently across different State services and platforms. 

  
  

• Rule 6 requires encryption, access controls, logging, and monitoring to be applied the same way across all systems, including those used by different vendors and processors. Automation helps eliminate inconsistent, department-specific security practices by ensuring the uniform application of these security measures. 

  
  

• When faced with regulatory checks, State agencies must show when data was accessed, for what purpose, and how it was protected. Automated logs, audit trails, and reports provide the necessary evidence to meet these requirements. 

  
  

7. How GoTrust Enables Automated State Data Processing Compliance 

   
   

Gotrust offers the technology needed to connect Section 7(b) with the 2025 Rules. Our platform is built to handle the complex tasks of compliance automatically, so government agencies can concentrate on delivering services effectively. 

1. Unified compliance layer for public-sector data processing 

GoTrust turns Section 7(b) and Rules 3 and 6 into real system rules, helping state organisations follow the law through automated policies. 

2. Purpose mapping across State services 

The platform links data sets to particular benefits, services, certificates, or licenses, making sure that data is only used in ways that are allowed under Section 7(b). 

3. Centralised and consistent notice management 

GoTrust lets state agencies send clear, service-specific notices that follow Rule 3, with the same updates across all websites and apps to avoid old or conflicting information.

4. Built-in security checks and tracking 

The platform works with existing systems to control who can access data, keep track of activity, and monitor it according to Rule 6, giving a clear view of who accessed data and why.

5. Processor and vendor oversight 

GoTrust helps oversee data processors by matching their contracts with Rule 6, ensuring all their activities are visible, controlled, and can be reviewed. 

8. Aligning Public Service Delivery with Digital Trust 

   
   

9. If we consider it in a complete way, Section 7(b) shows a policy decision that helps deliver public services efficiently without giving up data protection. Rules 3 and 6 make sure this efficiency is matched with transparency and security. Together, these rules mean that the government’s right to process data depends on the public’s trust. 

For citizens, trust grows when public services clearly explain how data is used, keep it safe, and offer real ways to get help if something goes wrong. For the government, trust makes it easier for people to use digital services, boosts how much people use them, and makes the government seem more reliable. Putting this trust into action needs systems that are built to enforce limits on data use, ensure transparency, and protect data by default. 

9. Conclusion 

Section 7(b) of the DPDPA allows the government to use personal data for important public services, but it doesn't give them unlimited power. When you look at it along with Rules 3 and 6 of the DPDP Rules, 2025, it shows that there are clear expectations for using data only for its intended purpose, and with strong security measures. For government agencies, following these rules is a crucial part of how they run their operations, which needs to be done consistently across all departments, services, and partners. 

Automation is the only way to keep up with this responsibility. Tools like GoTrust help turn legal requirements into real, enforceable rules, making sure that public services stay lawful, secure, and reliable. As digital management gets better, now is the time for government bodies to review their data handling practices and build compliance right into how they design their systems. Explore how GoTrust can help your organisation move toward compliant and trustworthy data handling.