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Personal data or sensitive data? A field-by-field guide.

Some details only identify you. Others can cost you money, dignity or safety if they leak. Here is how to tell them apart.

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Last reviewed: 26 October 2026. Procedures and timelines change, so confirm on the official sites linked below.

Personal data is any information that can identify you. Sensitive data is the part of it that does the most damage when it leaks. The table below shows the difference, field by field.

What the law actually says. The Digital Personal Data Protection Act, 2023 does not create a separate "sensitive data" category. It treats all digital personal data under one definition and applies its duties to all of it. The word "sensitive" comes from an older rule, the IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, which list specific categories. Those rules continue to apply while the DPDP Act is phased in, until about 13 May 2027. In the table, "high-risk" means data that is not named in that older list but deserves extra care in practice.

The comparison, field by field

Field Everyday personal data Sensitive data named in the 2011 rules Other high-risk data (not named)
Identity Name, date of birth, gender, nationality, a profile photo Not listed separately Aadhaar, PAN, passport, driving licence and voter ID numbers
Contact and login Email address, mobile number, postal address Passwords OTPs, PINs, security questions and answers
Money Employer name, the bank you use, what you bought and when Bank account details, credit and debit card details, other payment instrument details Salary and income records, loan and credit-score data, tax returns
Health Gym or yoga class membership Physical, physiological and mental health condition; medical records and history Fitness-tracker data that can reveal a condition; disability status
Body An ordinary photograph of your face Biometric information, such as fingerprints, iris scans, and face or voice templates used to identify you DNA and genetic data
Private life Language, hobbies, marital status, favourite brands Sexual orientation Religion, caste, political views, trade union membership
Location and online City, PIN code, IP address, device model, cookie ID Not listed separately Precise live location history, browsing and search history, private messages, call records
Family and children Names of family members you chose to share Not listed separately Any data about a child under 18 (the DPDP Act adds extra duties, see below)
Work Job title, office address, work email Not listed separately Background-verification results, performance and disciplinary records

The 2011 list also covers any detail about these categories that you hand to an organisation in order to receive a service. Information that is freely available in the public domain is excluded from that definition.

Three quick questions to classify any field

  1. Could someone use it to reach your money or accounts? Passwords, OTPs, card numbers and PINs all pass this test.
  2. Would its exposure reveal something private? Health, sexuality, beliefs, family and precise location are the usual examples.
  3. Can you change it after a leak? You can reset a password, but you cannot reset a fingerprint, a medical history or your Aadhaar number. The harder it is to change, the more carefully it should be handled.

If the answer to any of these is yes, treat the field as sensitive, whatever the law labels it.

Why the difference still matters

For individuals: share high-risk data only with organisations that explain why they need it, and never in response to an unsolicited call or message. Aadhaar numbers also have their own handling restrictions under the Aadhaar law.

For businesses: the DPDP Act requires reasonable security safeguards for all personal data, and the more harmful a leak would be, the stronger those safeguards should be. Failing to take them carries the highest maximum penalty in the Act, up to ₹250 crore (see Penalties). The volume and sensitivity of the data you hold is also one of the factors the government can use to designate a Significant Data Fiduciary.

For children's data: information about anyone under 18 gets extra protection under the Act whatever its type, including verifiable parental consent and limits on tracking. See Children's Data.

What to do next

If your data has been leaked or misused, see how to report a data breach. If you run a business and want to know which of these fields you hold and how well they are protected, the free DPDP Audit is a good starting point.

This page is general information, not legal advice. Whether a particular piece of data is treated as sensitive can depend on the law that applies to your sector, such as banking or health rules.