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/Glossary · Defined term

data

Defined in section 2(h) of the Act.

Official definition

Official definition

Verbatim

Act, section 2(h)

(h) “data” means a representation of information, facts, concepts, opinions or instructions in a manner suitable for communication, interpretation or processing by human beings or by automated means;

Interpretation in plain English

Interpretation · not legal advice
Interpretation, not legal advice. This is a plain-English interpretation of the official text, prepared by the DPDP Wiki editorial team. It is not the law and not legal advice, and it may be incomplete or wrong. Always rely on the official text of the Act, the Rules and the notifications, and take advice from a qualified professional for your situation.
Data FiduciaryData PrincipalData Processor

The Act defines "data" in a very broad way. It is not limited to numbers, spreadsheets, or computer code. Instead, "data" means any representation of information, facts, concepts, opinions, or instructions. This wide scope ensures that almost any recorded thought, fact, or directive can fall under the definition.

To count as data under this specific provision, the information must be represented in a manner that makes it suitable for communication, interpretation, or processing. This means the information must be in a format that allows it to be shared, understood, or worked with in some practical way.

Finally, the definition covers information that can be handled either by human beings or by automated means. This means data includes both formats meant for people to read and digital formats designed strictly for computers or machines to process. The focus is on how the information is represented and its suitability for being processed or communicated, regardless of whether a person or a machine is doing the work.

Key points

  • Data includes any representation of information, facts, concepts, opinions, or instructions [2(h)].
  • The information must be in a form suitable for communication, interpretation, or processing [2(h)].
  • Data can be in a format meant to be handled by human beings [2(h)].
  • Data also includes formats meant to be handled by automated means [2(h)].

Common misreadings

  • A reader might think data only refers to digital information processed by computers, but the definition explicitly includes information suitable for processing by human beings.
  • A reader might assume data only means hard facts, but the text clearly states it also includes concepts, opinions, and instructions.

Interpretation prepared from the official text only, 9 September 2026. The official text above prevails.

/MYND · DPDP practice

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