When India’s Digital Personal Data Protection (DPDP) Act began rolling out in phases from November 2025, much of the public conversation focused on big tech, e-commerce platforms and corporate data breaches. Yet one of the most immediate — and quietly transformative — impacts of the law is unfolding closer to home, inside apartment complexes and gated communities across the country.
For decades, Resident Welfare Associations (RWAs) and housing committees have collected and controlled vast amounts of personal data as part of routine administration. Identity proofs, phone numbers, vehicle details, CCTV footage, visitor logs, tenant KYC documents and payment histories were gathered almost by default, often stored casually on WhatsApp groups, Excel sheets or third-party apps with little oversight. The unspoken assumption was simple: if you live in a society, your data belongs to the society.
The DPDP Act fundamentally challenges that assumption. By formally recognising RWAs and housing committees as ‘data fiduciaries’, the law brings residential governance into the ambit of data protection regulation — introducing enforceable resident rights, legal accountability and a new balance of power within community living.
From Informal Control to Legal Accountability
Industry experts are of the view that housing societies were among the least regulated custodians of sensitive personal data. San Banerjee, co-founder and CEO of community management platform, ADDA.io, observes, “Residential ecosystems routinely processed far more information than most people realised, ranging from home addresses and visitor records to vehicle details and access logs, without structured safeguards.”
According to Banerjee, the DPDP Act addresses a long-standing vacuum by formalising how such data should be collected, stored and governed. Having worked across markets like the UAE and the US, where data protection laws are more mature, he sees India’s DPDP framework as a long-awaited alignment with global standards. The transition, however, requires behavioural change. ADDA.io has already conducted awareness workshops with over 500 housing societies, signalling how significant the shift will be for management committees accustomed to informal data practices.
Residents as Data Principals, RWAs as Fiduciaries
At the heart of the DPDP framework is a clear redefinition of roles. Residents are now legally recognised as data principals, with explicit rights over their personal data. RWAs and housing societies, by contrast, become data fiduciaries — entities responsible for determining why and how personal data is processed.
Santhosh Kumar, vice chairman, Anarock Group, describes this as a decisive break from past practices. “Earlier, community data management operated largely on discretion. Under DPDP, consent becomes foundational. Societies must now explain why data is being collected, restrict its use to stated purposes, and offer residents the right to access, correct or delete their information within defined timelines,” he states.
Crucially, the law limits secondary use of data without fresh consent, curbing discretionary power that committees often exercised without checks. In effect, data management shifts from being an administrative by-product to a governance obligation.
Power Rebalancing Inside Gated Communities
The consequences of this shift are already visible in cities with active RWAs and digitally enabled housing societies. Dipesh Garg, real estate advisor and co-founder, SouthDelhi1, points out that the DPDP Act is prompting difficult but necessary conversations within apartment complexes.
Long-standing practices such as retaining Aadhaar copies after verification, unrestricted access to CCTV footage, or indefinite storage of tenant data are now being questioned in AGMs and resident forums. In societies where committees traditionally enjoyed significant autonomy, the Act subtly redistributes power. Decisions around surveillance, access control and data sharing can no longer be unilateral; they must be transparent, purpose-driven and legally defensible.
Importantly, Garg stresses that this does not weaken governance. Instead, it introduces accountability where informality once prevailed, fostering trust through clarity rather than control.
Professionalising Community Management
Several stakeholders argue that the Act represents evolution rather than confrontation. Manju Yagnik, vice chairperson, Nahar Group and senior vice president, NAREDCO Maharashtra, believes, “The law modernises residential governance by embedding data protection into everyday decision-making.”
Apartment communities today rely heavily on technology — access management systems, digital payments, resident apps and security platforms. “By clearly defining responsibilities around data handling, the Act encourages RWAs to adopt more professional, process-driven systems. Rather than diminishing their authority, it helps them operate with greater credibility and legal clarity in an increasingly digital environment,” adds Yagnik.
This sentiment is echoed by Abhishek Tharwani, director, Tharwani Realty, who views DPDP as a natural response to the growing digitisation of housing. From his perspective, privacy-by-design — collecting only what is necessary, restricting access, and being transparent about usage — will ultimately improve efficiency and resident engagement. Structured systems, he argues, reduce redundancies and disputes rather than create friction.
Trust, Technology and Privacy-by-Design
The shift is also influencing how major developers and residential platforms approach community ecosystems. A Lodha Group spokesperson notes that trust will increasingly define the future of community living. “At BelleVie, we believe that the future of community living in India will be built as much on trust as on technology. As platforms begin managing deeply personal data — from visitor movements to payments and addresses — DPDP compliance cannot be treated as a regulatory formality, but must be embedded as a core design principle,” the spokesperson says.
A privacy-first approach, the spokesperson adds, ensures residents have transparency and control over their data, while RWAs, developers and enterprises gain confidence in partnering with platforms that are legally robust and future-ready.
Industry observers argue that in an increasingly crowded prop-tech ecosystem, responsible data governance is emerging as a key differentiator rather than a backend compliance function. Platforms that internalise DPDP-aligned practices — such as data minimisation, strict access controls and defined retention policies — are likely to scale more sustainably while preserving resident trust.
Tier 2 Cities and the End of ‘Society Property’ Thinking
The impact of DPDP is not limited to metros. Manoj Dhanotiya, founder and CEO, Micro Mitti, highlights how the law is reshaping apartment governance in tier 2 cities like Indore. Here too, RWAs historically treated resident data as collective property, with little distinction between necessity and convenience.
Under DPDP, that mindset is being dismantled. Residents now have enforceable rights to access, correction, erasure (where applicable) and grievance redressal. This shift introduces formal accountability, reduces misuse — such as selective leaks or harassment — and pushes societies toward SOP-led data handling, defined retention policies and tighter vendor controls.
Dhanotiya argues that far from weakening RWAs, the Act upgrades them into cleaner, more transparent institutions, better suited to contemporary urban living.
Legal Oversight Enters the Apartment Gate
From a legal standpoint, the DPDP Act’s deliberately broad definitions ensure that RWAs fall squarely within its scope. Supratim Chakraborty, partner, Khaitan & Co, explains, “Housing societies qualify as data fiduciaries because they determine the purpose and means of processing personal data, whether for security, administration or community management.”
This classification brings concrete obligations: clear notices, valid consent mechanisms, purpose limitation, security safeguards and grievance redressal processes. Importantly, RWAs remain liable even when data is processed by third-party vendors such as security agencies or apartment management apps. Contracts, access controls and oversight mechanisms will need to be revisited.
The introduction of external oversight — through the Data Protection Board if grievances remain unresolved — marks a decisive shift from self-governed discretion to regulated accountability.
Surveillance, Consent and the New Governance Ethic
Experts also note that DPDP directly affects how societies deploy surveillance technologies. Venket Rao, founder, Intygrat Law, points out, “CCTV systems, visitor tracking and facial recognition can no longer be justified purely on convenience or security rhetoric. Consent, proportionality and accountability now form part of governance ethics.”
Manav Agarwal, chief data and operations officer, Nklusive, adds that stronger data security standards will push societies away from informal tools toward auditable platforms. This, in turn, reduces disputes and builds resident trust — an essential currency in densely populated communities.
Challenges Ahead, but a Necessary Shift
There is broad consensus that compliance will require effort. RWAs will need to audit existing data, train staff, manage children’s data carefully, and balance security needs with consent requirements in real time. But many liken this transition to earlier reforms around financial transparency — initially resisted, eventually normalised and beneficial.
As Sanjeev Sachdeva, chief legal officer, Elan Group, observes, what was once seen as routine administration is now a defined legal responsibility. “The shift introduces discipline, clarity and balance into apartment governance,” he says.
A New Social Contract in Community Living
So, does the DPDP Act redefine apartment governance and rebalance power between RWAs and residents? The answer appears to be yes — but not as a zero-sum struggle. Instead, the Act reframes data as a matter of dignity, not convenience, and governance as stewardship rather than control.
By transforming RWAs from informal holders of resident data into accountable custodians, and residents from passive subjects into rights-bearing participants, the DPDP Act introduces a new social contract for community living. In an age where digital data is as sensitive as physical security, this shift is not just timely — it is inevitable.
