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Data Privacy Day: When Privacy Becomes Infrastructure

January 29, 2026 3 min. Read

As countries around the world strengthen data protection laws, the real test lies in turning privacy principles into a working digital infrastructure. Around the world, privacy frameworks are increasingly shaping how digital systems interoperate across jurisdictions. For example, the European Union and Brazil recently adopted mutual adequacy decisions that allow secure, unrestricted data flows between the EU and Brazil without additional safeguards, creating one of the largest areas of safe data transfers across borders and benefiting hundreds of millions of people.

In parallel, long-standing frameworks like the EU-US Data Privacy Framework enable compliant trans-Atlantic data flows between EU and U.S. organisations with recognised protection standards, underpinning trusted digital trade and cooperative economic activity. These developments reflect a global trend: privacy protection is not just a regulatory requirement but a strategic enabler of responsible data mobility and trust in a connected digital economy.

DPDP in Action: Privacy Built into the System

In India, the Digital Personal Data Protection (DPDP) framework marks a significant step toward giving individuals greater control over their personal data in the world’s largest democratic digital economy. The Account Aggregator (AA) ecosystem brings these DPDP principles — consent, purpose limitation, data minimisation, retention limits, transparency, and accountability — into daily practice. Every data flow in AA is anchored in explicit user consent, clear purpose definition, and structured limits on the type, range, and duration of data access.

Data access is time-bounded, traceable, and revocable, giving users agency and transparency over their financial information. Through the adoption of these privacy norms in both technical design and governance processes, the AA ecosystem demonstrates how DPDP principles can become an operational, enforceable infrastructure, beyond the legal text.

Privacy at Population Scale

What sets this model apart is that it operates at a national scale while preserving trust:

  • 20.82 million consents were successfully fulfilled in December
  • 371.13 million data shares occurred within consented boundaries
  • The ecosystem includes 176 Financial Information Providers, 880 Financial Information Users, and 17 operational Account Aggregators
  • Participation spans regulated sectors under RBI, SEBI, IRDAI, and PFRDA

These figures demonstrate that consent-driven, privacy-preserving data sharing is not an experiment — it is a real, large-scale digital infrastructure supporting sensitive financial interactions every day.

Ecosystem Initiatives for Customer Protection

In support of customer data protection and AA ecosystem integrity, Sahamati has driven key initiatives adopted across the AA community. Codes of Conduct provide actionable guidelines for FIUs, AAs, and FIPs, supported by checklists and onboarding procedures. The Fair Use Template Library, developed with industry experts in various Councils and the Fair Use Committee anchored by Sahamati, sets agreed upper bounds on consent attributes to ensure responsible, transparent data use. Sahamati’s Certification Framework verifies that the ecosystem participants conform with ReBIT’s open API standards, enhancing trust and technical interoperability across the ecosystem. Likewise, the AA Redirection Guidelines and network-level common infrastructure like Sahamati’s Central Registry and Token Service provide industry discipline and technical guardrails to reinforce consent‑based, privacy‑respecting data sharing.

Looking Ahead: Building Stronger Trust

As services and systems become more interconnected, user privacy will remain foundational to digital trust. Our shared vision with the community is to continue our focus on:

  • Making consent interfaces understandable to all users
  • Keeping purpose boundaries clear, proportionate, and verifiable 
  • Ensuring consistent technical standards across participants
  • Extending privacy-first thinking into all processes

Data Privacy Day is a reminder that privacy is not about stopping data from moving — it is about ensuring that data flows with accountability, restraint, and user agency.

When privacy becomes part of the system’s architecture rather than an afterthought, trust stops being a slogan — and becomes a feature of the digital economy.

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