DPDP Rules 2025 notified — enforceable 13 May 2027.|Time left: –d –h –m –s
Primary text — Rule 20

20. Functioning of Board as digital office. — The Board shall function as a digital office, without prejudice to its power to summon and enforce the attendance of any person and examine her on oath, may adopt techno-legal measures to conduct proceedings in a manner that does not require physical presence of any individual.

Our interpretation

Rule 20 states that the Board shall function as a digital office and, without prejudice to its power to summon and enforce the attendance of any person and examine her on oath, may adopt techno-legal measures to conduct proceedings in a manner that doesn't require any individual's physical presence. It's a short rule, but the two clauses inside it matter separately.

Digital by default, not digital-only

The rule authorises the Board to run its proceedings — receiving complaints, hearing matters, issuing decisions — through techno-legal measures rather than requiring anyone to appear in a physical office. That's consistent with Section 28(1) of the Act, which already requires the Board to function as a digital office "as far as practicable" and describes complaint receipt, allocation, hearing and decision-pronouncement as "digital by design."

The explicit carve-out is what keeps this from being read as a blanket substitute for in-person process: nothing about running digitally limits the Board's power to summon and enforce someone's attendance and examine her on oath. If a matter genuinely calls for that kind of examination, the digital-office framing doesn't stand in the way of it.

Why this matters in practice

For an organisation dealing with the Board — whether responding to an inquiry, filing a submission, or attending a hearing — Rule 20 sets the practical expectation that most interactions will happen through digital channels rather than requiring travel or physical filing. It's worth building an internal process around that assumption: designated personnel who can respond to Board communications promptly through whatever digital mechanism the Board specifies, rather than assuming a written letter or an in-person visit is how the process runs. At the same time, an organisation shouldn't assume digital-office status means it can never be summoned in person — that power stays fully intact under this same rule.

Illustration: a company under Board inquiry receives all its correspondence — notices, requests for information, hearing schedules — through a digital portal or electronic communication, and its representatives appear at any hearing via video conferencing rather than travelling to a physical office. If the Board decides a particular witness needs to be examined on oath, though, it can still summon that person specifically, regardless of how digital the rest of the process has been.

How Rule 20 connects to the rest of the Rules and the Act

Rule 20 operationalises Section 28(1) of the Act, which sets the Board's own general obligation to function as a digital office and lists the specific activities — complaint receipt, allocation, hearing, decision — that should be digital by design. It pairs closely with Rule 19's meeting-and-inquiry procedures, since those meetings, circulations and the six-month inquiry clock under Rule 19(9) are all things the Board conducts through this same digital-office framework. The Appellate Tribunal that hears appeals from Board orders operates under a parallel digital-office requirement of its own — covered in Rule 22 and Section 29(10) of the Act — so the "no physical presence required" principle runs through both stages of the process, not just the Board's own inquiries.

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