If you are evaluating RCS messaging for your business in India, one of the first questions your compliance or legal team will ask is simple: what are the data protection rules? This guide walks through what India's Digital Personal Data Protection Act, 2023 (DPDP Act) means for a business running RCS campaigns- consent, data rights, and good-practice habits, explained in plain English.
This article is general informational guidance, not legal advice. It's written to help businesses understand how the DPDP Act relates to RCS messaging in plain terms. Rules and enforcement timelines under the Act can change, and how they apply depends on your specific business- please consult your own legal or compliance counsel, and check the Ministry of Electronics and Information Technology's (MeitY) official notifications for the latest position before making compliance decisions.
Quick answer: The DPDP Act treats a business sending RCS messages to a customer's phone number as a Data Fiduciary processing that customer's personal data. That means consent for how the number was collected, honouring opt-outs, and being able to respond to access or erasure requests all matter for RCS campaigns- alongside, not instead of, Google's separate sender-verification process covered in our RCS brand verification guide.
What the DPDP Act Actually Says
The Digital Personal Data Protection Act, 2023 is India's comprehensive personal data protection law, administered under MeitY. In plain terms, it sets out rules for how organisations can collect, use, and store personal data belonging to individuals- and what those individuals can ask for in return.
At its core, the Act requires that personal data generally be processed on the basis of consent, or a specified legitimate use, and that consent be free, specific, informed, unconditional, and unambiguous, with a clear affirmative action from the individual. It also requires organisations to implement reasonable security safeguards around the data they hold, and to report personal data breaches when they occur. A Data Protection Board of India is established to handle enforcement and grievances.
None of this is unique to messaging- it applies broadly across how Indian businesses handle customer data. But because RCS campaigns run on a customer's phone number and often a name or profile, they sit squarely inside what the Act is designed to cover.
Data Fiduciary vs Data Principal
The Act defines two roles that map directly onto any RCS campaign- the sender and the recipient.
- Data Fiduciary (your business)- the entity that decides why and how personal data is processed. A business sending RCS messages using customer phone numbers and names is acting as a Data Fiduciary under the DPDP Act.
- Data Principal (your recipient)- the individual the data belongs to. Everyone on your RCS messaging list- customers, leads, users- is a Data Principal with rights over how their data is used.
Consent and RCS Messaging
The Act's consent standard- free, specific, informed, unconditional, and unambiguous, with a clear affirmative action- maps naturally onto how a business collects a phone number for messaging. A number picked up incidentally, without a clear opt-in for messaging specifically, sits on shakier ground than one collected through an explicit checkbox, form field, or app permission that says what the customer is signing up for.
In practice, that means it's worth being able to answer: where did this number come from, did the customer clearly agree to receive messages, and can you show that record if asked? Consent can generally be withdrawn as easily as it was given, so an opt-out or "STOP" request should be honoured promptly and reflected in your send list- not just logged and forgotten.
This is a good-practice framing, not a legal checklist- how consent requirements apply to your specific messaging program is worth confirming with your own counsel.
What Your Recipients Can Ask For
These rights translate into concrete, practical requests a business should be ready to handle for anyone on its messaging list:
- Right to access information- a Data Principal can ask what personal data a business holds and how it's being processed, including for messaging purposes.
- Right to correction- a recipient can ask you to correct inaccurate or outdated personal data, such as a wrong phone number or name on file.
- Right to erasure- a recipient can ask you to delete personal data once it's no longer needed for the purpose it was collected for, including removal from a messaging list.
- Right to grievance redressal- a recipient can raise a grievance directly with the business, and escalate to the Data Protection Board of India if it isn't resolved.
RCS's Verified Sender Identity: Complementary, Not a Substitute
RCS's Google-verified sender badge is a genuine trust and anti-spoofing feature- it confirms to a recipient that a message really comes from the business it claims to, using the review process covered on our RCS brand verification page. That's valuable, but it answers a different question than the DPDP Act does.
Verification proves who is sending a message. It does not, by itself, say anything about whether that sender had proper consent to collect the recipient's number, how long it plans to retain that data, or whether it can honour an erasure request. Treat the two as complementary layers of a trustworthy messaging program- one about sender identity, the other about how you handle the data behind that identity. Sending behaviour that erodes trust in other ways can also affect your RCS agent's reputation standing, which is a separate but related concern from data protection.
Why Your Messaging Vendor's Security Practices Matter
The DPDP Act places breach-notification obligations on Data Fiduciaries when personal data they hold is compromised. For an RCS sender, that personal data typically lives partly with your messaging platform- phone numbers, message content, and delivery logs all pass through it. That makes your vendor's security practices around that data part of your own preparedness picture, not just a technical detail.
Get Click Media follows data-handling practices designed to support customers' own compliance obligations- this is a description of platform practices, not a certified compliance guarantee. Confirm your specific breach-notification obligations with your own legal counsel.
A Good-Practice Checklist for RCS Senders
These are sensible habits that support a DPDP-style mindset- not a legal checklist, and not a guarantee of compliance:
- Document consent capture. Keep a record of when and how a customer opted in to receive messages- a form, checkbox, or app permission- rather than relying on memory.
- Honour opt-outs promptly. Build a process to act on STOP requests or unsubscribe clicks quickly, and remove those recipients from future sends.
- Practise data minimisation. Collect and retain only the personal data your messaging actually needs, and avoid holding recipient data longer than the purpose requires.
- Have a request-handling process. Know who on your team handles an access, correction, or erasure request, and how quickly you can act on it.
- Choose vendors with sound security practices. Your messaging platform holds message logs and recipient data on your behalf- its security posture is part of your own data-handling picture.
- Get verified, but don't stop there. Google's verified sender badge builds recipient trust, but treat it as one part of a broader data-handling approach, not a compliance substitute.
The Bottom Line
The DPDP Act gives Indian businesses a clear framework for how personal data- including the phone numbers and names behind an RCS campaign- should be collected, used, and protected. None of it is a reason to avoid RCS; if anything, a channel built around a verified sender identity and rich, transparent messaging is a natural fit for a consent-conscious messaging program. The businesses best positioned as enforcement matures are the ones building good consent and data-handling habits now, alongside the Google verification process they already complete to send RCS at all.
This article provides general informational guidance on the current regulatory landscape for the DPDP Act as it relates to RCS Business Messaging in India and should not be treated as legal advice. Businesses with specific compliance questions, particularly in regulated sectors, should consult qualified compliance counsel.
Get Click Media is one of India's leading RCS messaging service providers, with direct carrier integrations with Jio, Airtel, and Vi. We manage Google brand verification, build consent and opt-out handling into every campaign, and help clients apply sound data-handling practices across their messaging programs. Request a demo to see how our platform supports responsible RCS messaging at scale.
Frequently Asked Questions
The Digital Personal Data Protection Act, 2023 (DPDP Act) is India's comprehensive personal data protection law, administered under the Ministry of Electronics and Information Technology (MeitY). It applies to the processing of personal data generally, and sending RCS messages to a customer's phone number- along with any name or profile data attached to that conversation- counts as processing personal data, so the Act's principles are relevant to RCS campaigns.
The DPDP Act requires that personal data generally be processed on the basis of consent (or a specified legitimate use) that is free, specific, informed, unconditional, and unambiguous, with a clear affirmative action. For marketing-style RCS messages, that means having a genuine opt-in on record is a sound practice rather than assuming permission because you have someone's number. This is general guidance, not legal advice- confirm your specific consent requirements with your own counsel.
A Data Fiduciary is the entity that determines the purpose and means of processing personal data. A business that decides to send RCS messages to its customers, and controls what data is collected and how it's used for that messaging, is generally acting as a Data Fiduciary with respect to that data.
No. Google's RCS brand verification confirms who is sending a message- it's a genuine anti-spoofing and trust feature- but it says nothing about how a business collected consent for a recipient's number or how it handles that person's data afterward. Verification is complementary to DPDP-style obligations, not a substitute for them.
Under the DPDP Act's framework, a Data Principal generally has a right to request erasure of personal data once it's no longer needed for the purpose it was collected for. In practice for an RCS sender, that typically means having a process to suppress or remove that person from your messaging lists and confirm the request was actioned. Exact obligations depend on your situation- check with your legal/compliance counsel.
Get Click Media follows data-handling practices designed to support customers' own compliance obligations- for example, around message logs and recipient data security- but we don't present this as a certified or audited legal compliance service. DPDP compliance for your messaging program is ultimately your business's responsibility, and we'd encourage you to review your own obligations with legal counsel.
Both are comprehensive personal data protection frameworks built around consent and individual rights, but they are separate laws from separate jurisdictions- the DPDP Act is India's law administered by MeitY, while GDPR is the European Union's regulation. The specific obligations, terminology, and enforcement mechanisms differ, so compliance with one doesn't automatically mean compliance with the other.
The DPDP Act establishes a Data Protection Board of India for enforcement and grievance handling. As of August 2026, the Act's rules are being operationalised in phases- check the Ministry of Electronics and Information Technology's official notifications for the current implementation timeline rather than relying on any fixed date.
Yes- under the DPDP Act's framework, consent can generally be withdrawn as easily as it was given. For an RCS sender, that means honouring an opt-out or unsubscribe request as promptly as you processed the original opt-in.
The DPDP Act places breach-notification obligations on Data Fiduciaries when personal data is compromised. Because your RCS platform holds recipient phone numbers and message logs on your behalf, its security practices are part of how well-prepared your business is to meet this kind of obligation- though exact notification requirements should be confirmed with your own counsel.
