DPDP Bill 2023 A Comparative Analysis
Introduction
THE DIGITAL PERSONAL DATA PROTECTION BILL, 2022 Released for Public Consultation on November 18, 2022THE DIGITAL PERSONAL DATA PROTECTION BILL, 2023Tabled at LokSabha on August 03. 2023Personal data may be processed only for a lawful purpose for which an individual has given consent. Consent may be deemed in certain cases.The 2023 bill imposes reasonable obligations on data fiduciaries and data processors to safeguard digital personal data.There is a Data Protection Board under the 2022 bill to deal with the non-compliance of the Act.Under the 2023 bill, there is the Establishment of a new Data Protection Board which will ensure compliance, remedies and penalties.
Under the new bill, the Board has been entrusted with the power of a civil court, such as the power to take cognisance in response to personal data breaches, investigate complaints, imposing penalties. Additionally, the Board can issue directions to ensure compliance with the act.The 2022 Bill grants certain rights to individuals, such as the right to obtain information, seek correction and erasure, and grievance redressal.The 2023 bill also grants More Rights to Individuals and establishes a balance between user protection and growing innovations. The bill creates a transparent and accountable data governance framework by giving more rights to individuals. In the 2023 bill, there is an Incorporation of Business-friendly provisions by removing criminal penalties for non-compliance and facilitating international data transfers.
The new 2023 bill balances out fundamental privacy rights and puts reasonable limitations on those rights.Under the 2022 bill, Personal data can be processed for a lawful purpose for which an individual has given his consent. And there was a concept of deemed consent.The new data protection board will carefully examine the instance of non-compliance by imposing penalties on non-compiler.The bill does not provide any express clarity in regards to compensation to be granted to the Data Principal in case of a Data Breach.Under 2023 Deemed consent is there in its new form as ‘Legitimate Users’.The 2022 bill allowed the transfer of personal data to locations notified by the government.There is an introduction of the negative list, which restricts cross-data transfer.
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Executive Summary:
A viral online video claims Canadian Prime Minister Justin Trudeau promotes an investment project. However, the CyberPeace Research Team has confirmed that the video is a deepfake, created using AI technology to manipulate Trudeau's facial expressions and voice. The original footage has no connection to any investment project. The claim that Justin Trudeau endorses this project is false and misleading.

Claims:
A viral video falsely claims that Canadian Prime Minister Justin Trudeau is endorsing an investment project.

Fact Check:
Upon receiving the viral posts, we conducted a Google Lens search on the keyframes of the video. The search led us to various legitimate sources featuring Prime Minister Justin Trudeau, none of which included promotion of any investment projects. The viral video exhibited signs of digital manipulation, prompting a deeper investigation.

We used AI detection tools, such as TrueMedia, to analyze the video. The analysis confirmed with 99.8% confidence that the video was a deepfake. The tools identified "substantial evidence of manipulation," particularly in the facial movements and voice, which were found to be artificially generated.



Additionally, an extensive review of official statements and interviews with Prime Minister Trudeau revealed no mention of any such investment project. No credible reports were found linking Trudeau to this promotion, further confirming the video’s inauthenticity.
Conclusion:
The viral video claiming that Justin Trudeau promotes an investment project is a deepfake. The research using various tools such as Google Lens, AI detection tool confirms that the video is manipulated using AI technology. Additionally, there is no information in any official sources. Thus, the CyberPeace Research Team confirms that the video was manipulated using AI technology, making the claim false and misleading.
- Claim: Justin Trudeau promotes an investment project viral on social media.
- Claimed on: Facebook
- Fact Check: False & Misleading
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Introduction
In today's digital economy, data is not only a business asset but also the fuel for innovation, decision-making, and consumer trust. However, the digitisation of services has made personal or sensitive data a top target for cybercriminals. The stakes are high: a data breach can cost millions of fines, cause damage to reputation and devastate the confidence of consumers. Therefore, regulatory compliance and data protection have become a strategic imperative.
From the General Data Protection Regulation (GDPR) in the EU to the Digital Personal Data Protection (DPDP) Act of India, various sector-specific regulations like HIPAA for healthcare in the US, companies are now subject to a web of data protection and compliance laws. The challenge is to balance compliance efforts with strong security, a balance that demands both policy restraint and technical resilience. This blog examines pivotal pillars, shifting trends and actionable best practices for dominating data protection and compliance in 2025 and beyond.
Why Data Protection and Compliance Matter More Than Ever
Data protection isn't just about keeping fines at bay, it's about preserving the relationship with customers, partners and regulators. A 2024 IBM report says the average data-breach cost has now exceeded USD 4.5 million, with regulatory fines constituting a large portion of the cost. In addition to economics, breaches tend to result in intellectual property loss, customer loss and long-term brand attenuation. Compliance ensures organisations remain within certain legislative necessities for collecting, holding, transferring and setting of personal and sensitive information. Failure to conformity can lead to serious penalties: under GDPR, fines could be up to 4% of the company's annual turnover or €20 million, whichever is higher. In regulated sectors like banking and healthcare, compliance breaches can also lead to the suspension of licenses.
Important Regulatory Frameworks Informing 2025
- GDPR and Its Global Ripple Effect
GDPR was enacted in 2018 and continues to have a ripple effect on privacy legislation worldwide. Its tenets of lawfulness, transparency, data minimisation and purpose limitation have been replicated in many jurisdictions such as Brazil's LGPD and South Korea's PIPA.
- India's DPDP Act
The DPDP Act, 2023, gives high importance to consent-based processing of data, transparent notice rules and fiduciary responsibilities for data. With a penalty for default of up to INR 250 crore, it's amongst the most impactful laws for digital personal data protection.
- Sectoral Regulations
- HIPAA for healthcare information in the US.
- PCI DSS for payment card security.
- DORA (Digital Operational Resilience Act) in the EU for financial organisations.
- These industry-specific models generate overlapping compliance responsibilities, making cross-enterprise compliance programs vital.
Key Pillars of a Sound Data Protection & Compliance Program
- Data Governance and Classification
Having insight into what data you have to store, where it is stored and who can have access to it is the keystone of compliance. Organisations need to have data classification policies in place to group information based on sensitivity and impose more rigorous controls on sensitive data.
- Security Controls and Privacy by Design
Strong technical defences, encryption, multi-factor authentication, and intrusion detection are the initial defences. Privacy by design integrated in product development guarantees compliance is thought through from the initial stage, not added on afterwards.
- Consent and Transparency
Contemporary data legislation highlights informed consent. This entails simple, non-technical privacy notices, detailed opt-in choices, and straightforward withdrawal options. Transparency produces trust and lessens legal danger.
- Incident Response and Breach Notification
Most laws demand timely breach notifications, and GDPR insists on reporting within 72 hours. Having a documented incident response plan maintains legal deadlines and reduces harm.
- Employee Training and Awareness
Human mistake is the top source of data breaches. Ongoing training in prevention of phishing, password management, basic cyber hygiene and compliance requirements is crucial.
Upcoming Trends in 2025
- AI-Powered Compliance Monitoring
Organisations are embracing AI-powered solutions to systematically monitor data flows, identify policy breaches and auto-create compliance reports. The solutions assist in closing the loop between IT security teams and compliance officers.
- Cross-Border Data Transfer Mechanisms
With increasingly severe regulations, companies are spending more on secure cross-border data transfer frameworks like Standard Contractual Clauses (SCCs) and Binding Corporate Rules (BCRs).
- Privacy-Enhancing Technologies (PETs)
Methods such as homomorphic encryption and differential privacy are picking up steam, enabling organisations to sift through datasets without revealing sensitive personal data.
- ESG and Data Ethics
Data handling is increasingly becoming a part of Environmental, Social and Governance (ESG) reporting. Ethical utilisation of customer data, not just compliance, has become a reputational differentiator.
Challenges in Implementation
Despite having transparent frameworks, data protection plans encounter challenges like jurisdictions having competing needs, and global compliance is becoming expensive. The emerging technologies, such as generative AI, often bring privacy threats that haven’t been fully covered by legislation. Small and micro enterprises have neither the budget nor the skills to implement enterprise-level compliance programs. Qualifying these challenges often needs a risk-based strategy, allocations of resources to top areas of impact and automating the compliance chores wherever possible.
Best Practices for 2025 and Beyond
In 2025, regulatory compliance and data protection are no longer a precaution or a response to a breach but are strategic drivers of resilience and trust. As regulatory analysis rises, cyber threats evolve, and consumer expectations grow, administrations need to integrate compliance into the very fabric of their actions. By bringing governance and technology together, organisations can break free from a "checklist" mentality and instead adopt a proactive and risk-sensitive approach. Eventually, data protection is not just about not getting in trouble; it's about developing a kind that succeeds in the digital era.
References
- GDPR – Official EU Regulation Page: https://gdpr.eu
- India’s DPDP Act Overview – MeitY: https://www.meity.gov.in/data-protection-framework
- HIPAA – US Department of Health & Human Services: https://www.hhs.gov/hipaa
- PCI DSS Standards: https://www.pcisecuritystandards.org
- IBM Cost of a Data Breach Report 2024: https://www.ibm.com/reports/data-breach
- OECD – Privacy Guidelines: https://www.oecd.org/sti/privacy-guidelines

Introduction
In recent years, the online gaming sector has seen tremendous growth and is one of the fastest-growing components of the creative economy, contributing significantly to innovation, employment generation and export earnings. India possesses a large pool of skilled young professionals, strong technological capabilities and a rapidly growing domestic market, which together provide an opportunity for the country to assume a leadership role in the global value chain of online gaming. With this, the online gaming industry has also faced an environment of exploitation, abuse, with notable cases of fraud, money laundering, and other emerging cybercrimes. In order to protect the interests of players, ensure fair play and competition, safe and secure online gaming environment, the need for introducing and establishing dedicated gaming regulation was a need of the hour.
On 20 August 2025, the Union government introduced a new bill, ‘Promotion and Regulation of Online Gaming Bill, 2025’ in Lok Sabha that seeks to prohibit online money gaming, including advertisements and financial transactions related to such platforms. From the introduction, the said bill was passed at 5 PM on the same date. Further, the upper house of parliament (Rajya Sabha) passed the bill on 21st August 2025. The bill can be seen as a progressive step towards building safer online gaming spaces for everyone, especially for our youth and combating the emerging cybercrime threats present in the online gaming landscape.
Key Highlights of the Bill
The Bill extends to the whole of India. It also applies to any online money gaming service offered within India or operated from outside the country but accessible in India.
- Definition of E-sports:
Section 2(1)(c) of the Bill defines e-sports as:-
(i) is played as part of multi-sports events;
(ii) involves organised competitive events between individuals or teams, conducted in multiplayer formats governed by predefined rules;
(iii) is duly recognised under the National Sports Governance Act, 2025, and registered with the Authority or agency under section 3;
(iv) has outcome determined solely by factors such as physical dexterity, mental agility, strategic thinking or other similar skills of users as players;
(v) may include payment of registration or participation fees solely for the purpose of entering the competition or covering administrative costs and may include performance-based prize money by the player; and
(vi)shall not involve the placing of bets, wagers or any other stakes by any person, whether or not such person is a participant, including any winning out of such bets, wagers or any other stakes;
- Prohibition of Online Money Gaming and Advertisement thereof
The Bill prohibits the offering of online money games and online money gaming services. It also bans all forms of advertisements or promotions connected to online money games. This includes endorsements by individuals or entities. - Financial Transactions
Banks, financial institutions, and other intermediaries are barred from facilitating transactions related to online money gaming services. - Criminal Liability
Violation of the provisions on online money gaming can result in imprisonment for up to three years, or a fine of up to ₹1 crore, or both. Repeat offenders face stricter punishment with higher fines and longer jail terms. - Cognizable and Non-Bailable Offences
Offences relating to offering online money gaming services and facilitating financial transactions for such games are categorised as cognizable and non-bailable. This gives law enforcement agencies greater power to act without requiring prior approval.
In conversation with CyberPeace ~
Shailendra Vikram Singh, Former Deputy Secretary (Cyber & Information Security), Ministry of Home Affairs, GOI . He highlighted that
"The passage of the Promotion and Regulation of Online Gaming Bill, 2025 in the Lok Sabha highlights the government’s growing priority on national security, public safety, and health in digital regulation. Unfortunately, the real money gaming industry, despite its growth and promise, did not take proactive steps to address these concerns. The absence of safeguards and engagement left the government with no choice but to adopt a blanket ban."Having worked on this issue from both the government and industry side, the clear lesson is that in sensitive digital sectors, early regulatory alignment and constructive dialogue are not optional but essential. Going forward, collaboration is the only way to achieve a balance between innovation and responsibility.”
CyberPeace Outlook
The Promotion and Regulation of Online Gaming Bill, 2025, marks a decisive policy shift by simultaneously fostering the growth of e-sports, educational and social gaming, and imposing an absolute prohibition on online money games. By recognising e-sports as legitimate, skill-based competitive sports under the National Sports Governance Act, 2025, and establishing a central Authority for oversight, registration, and regulation, the Bill creates an institutional framework for safe and responsible development of the sector. The Bill completely bans real money games (RMGs), regardless of whether they are skill-based or chance-based or both, hence it poses significant questions on RMG companies' legal standing, upon which the gaming industry has raised its conundrum. Further, it addresses urgent threats such as cybercrime, gaming addiction, online betting, money laundering, and the misuse of gaming platforms for illicit activities. The move reflects a balanced approach, encouraging innovation and digital skill-building, while safeguarding public order, consumer interests, and financial integrity.
References
- https://prsindia.org/files/bills_acts/bills_parliament/2025/Bill_Text-Online_Gaming_Bill_2025.pdf
- https://prsindia.org/billtrack/the-promotion-and-regulation-of-online-gaming-bill-2025
- https://www.hindustantimes.com/india-news/rajya-sabha-clears-online-gaming-bill-a-day-after-lok-sabha-approval-101755766847840.html