Section 25 — Members and officers to be public servants

What this section requires

The Chairperson, Members, officers and employees of the Board are deemed public servants under Section 21 of the Indian Penal Code while acting or purporting to act under the Act.

Who it applies to

The Chairperson, Members, officers and employees of the Board — this affects their own criminal-law status, not a Data Fiduciary obligation.

Checklist

• Not applicable — a public-servant deeming provision carries no fiduciary-facing checklist.

Penalty exposure

Not applicable — no Schedule item attaches to this deeming provision. It is, however, what makes bribery or obstruction of a Board official a public-servant offence under the Indian Penal Code, separately from the DPDP Act.

Implementation timeline

In force since 13 November 2025.