The Government of Karnataka is undertaking its highly anticipated Socio-Economic and Educational Survey or the “Caste Census”, where citizens are signing self-declaration forms that obtain consent based on the Digital Personal Data Protection (DPDP) Act, 2023 and its draft rules.
Speaking to MediaNama, Apar Gupta, Founder Director of the Internet Freedom Foundation (IFF), highlighted the flaws in this consent process.
“The DPDP Act is not yet in force, and no commencement notification has been issued. So any ‘consent’ language on these forms that cites the DPDP Act has no statutory footing.
“It’s merely black ink on a white page, not a legally enforceable right. [Also] references to ‘DPDP Rules’ are wholly misconceived because there is no final, notified set of rules in the public domain,” he remarked.
Importantly, the Government of Karnataka is using this legally questionable process to collect a vast trove of sensitive personal, financial, and political data. And this raises urgent questions about the validity of the consent and the security of citizens’ information. Notably, the nature of the consent seeking process fails to meet the requirements of the very law that it refers to.
For context, I first came across the self-declaration form while filling out the caste census details for my own household, and a reference to the DPDP Act in the last line immediately stood out.
Interestingly, the enumerator did not know why this reference was made, and this prompted a deeper examination of the Social and Educational Survey Handbook 2025, which contains references to both the DPDP Act and Rules.
About the Survey
The Social and Educational Survey 2025 is being led by the Karnataka State Commission for Backward Classes. The Karnataka Government plans to survey nearly 7o million people across 20 million households. The project aims to collect “accurate social and educational data” using a mobile app developed by the Directorate of Electronic Delivery of Citizen Services (EDCS).
Notably, this is Karnataka’s second caste census. For context, the state government had shelved the 2015 survey’s recommendations in July this year.
The Karnataka High Court (HC) allowed the current survey to proceed despite legal challenges by stating two vital caveats. This includes making citizen participation purely voluntary and ensuring confidentiality for the collected data.
Three Versions of the Self-Declaration Forms
Enumerators administer the self-declaration forms to survey respondents after the completion of the data collection process. This is to mark their voluntary participation in the survey. A close review of these forms and survey documents shows that officials have framed consent poorly.
Medianama obtained a physical copy of the self-declaration form, which officials administer after completing the survey….
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