The National Payments Corporation of India (“NPCI”) vide an operating circular published on July 5, 2022 (“Circular”) has provided guidelines on capturing customer location on Unified Payments Interface (“UPI”) applications.
UPI applications operate based on an Application Programming Interface (“API”) framework, where geo tagging (location/geocode) information of the payment is captured while initiating a transaction. These location details along with other relevant customer data need to be captured within the app providers system in an encrypted format. Since geo-tagging involves customer centric information and such data points are sensitive information, the relevant guidelines are necessary to be strictly followed by all UPI members.
The Circular provides the following guidelines:
1. UPI applications are only allowed to capture location/ geographic details with the consent of the customer/ individual, and the same cannot be made a mandatory feature.
2. If the customer had initially given consent to share their location with the UPI application while availing their services, the option for subsequently revoking such consent should also be provided. UPI services should be continued to be provided even if customer has revoked consent for sharing location/ geographical details.
3. In cases where consent has been given by the customer to capture location/ geographic details, the same should be correctly passed to UPI. Any incorrect details passed will attract strict action from the NPCI.
4. No UPI services shall be disabled or withheld from the customer if consent for sharing any location/geographic details has not been permitted.
5. These guidelines will be applicable where the customer (payer) is a person/ individual who is initiating the transaction and will be applicable to domestic UPI transactions only.
All UPI members are required to comply with the guidelines by December 1, 2022.
Please find a copy of the Circular here.
This update has been contributed by Aastha, Partner and Rohan Mitra (Associate).
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