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DPDPA Compliance for HRTech Platforms

Employee Data Processing in Digital HR

8 min read25 November 2024
"HRTech platforms are Data Processors for thousands of employer-clients. Scalable compliance is existential."

HRTech platforms—HRMS, payroll, recruitment—process employee data on behalf of employer-clients. This multi-tenant processing model creates complex compliance requirements.

1HRTech Compliance Architecture

Understand your role in the data protection ecosystem.

  • Employer is Data Fiduciary for employee data
  • HRTech platform is Data Processor
  • Employee is Data Principal
  • DPA required between employer and HRTech platform
  • Employee rights exercised against employer, not platform

2Employment Legitimate Use

Section 7(e) provides processing basis for employment data.

  • Payroll processing: Legitimate use
  • Performance management: Legitimate use
  • Background checks: May require consent
  • Biometric attendance: Requires consent
  • Health benefits: Requires explicit consent
Counsel Advisory

Platform Guidance: Help your employer-clients understand when consent vs. legitimate use applies. Provide configurable consent workflows.

Key Takeaways

1

HRTech platforms are Data Processors, not Fiduciaries

2

Employment legitimate use covers most HR processing

3

Sensitive data (health, biometric) requires consent

4

DPAs with employer-clients are mandatory

5

Multi-tenant isolation is critical for breach containment

Statutory References

Section 7(e) (Employment)Section 8(7) (Processor)Section 9 (Sensitive Data)Rule 6 (Security)

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