In today’s World remote onboarding has become the new standard in India’s tech hybrid workplace ecosystem, and in such cases safeguarding Personally Identifiable Information (PII) particularly Aadhaar and PAN details becomes a critical compliance and trust-building priority for every organization either it’s a small business, medium enterprise or any tech giant.
In this article, I will provide you a step by step roadmap on protecting your employees’ data based on my own 9+ years corporate experience that grounds with the real-world practices and compliance standards. Our main moto through this blog is to help small companies and businesses to establish a secure, scalable and compliant onboarding processes. In my 9 years of experience I have worked with SMEs, tech startups and tech giants like HCLtech where I learned on how enterprise HR systems works in India and how it is shaped by current legal mandates under the IT Act, Aadhar Act, and evolving DPDP 2023 Bill guidelines.
Why it matters?
There’s no debate on how Aadhaar and PAN data are way sensitive markers in our day to day life in our country. Any unauthorized access, mishandling, or breaches can in fact directly lead to the legal consequences, financial losses, reputational damage of the organization and what not. Now when we talk about onboarding that too often with the fully digital process where data flows through multiple endpoints and often outside traditional office perimeters increases exposure if not secured properly. By implementing the right security measures, organizations can minimize the the risks associated in the Aadhaar and PAN data leak. Keeping sensitive data protected in the first place does not only safeguards the organizations data but it also contributes in building the trust for that organization, maintaining the brand value and increases the productivity of the organization.
Best practices for Aadhaar and PAN data collection:
The first and most basic precaution that we can start taking is from the beginning of the enrollment process that is the collection of the basic details of the employee that also includes Aadhaar and PAN card details. Collection of the Aadhaar and PAN data from a remote employee should follow some golden rules.
1. Avoid collecting Aadhaar and PAN card details via Whatsapp or Email attachments, now why does this even matters? The reason is whenever we share the attachments via Whatsapp there are very high chances that the recipient can screenshot the attachment or forward it to somewhere else. And not to forget that if the employee’s or the HR person’s phone device gets compromised like malware, theft, or unauthorized access then your Aadhaar and PAN data can be accessed easily. Also, if you share Aadhaar and PAN data via email attachment then interception can become your enemy where if the email’s transit is not encrypted (e.g., using S/MIME or PGP, which is uncommon for average users).
Additionally, data retention is one of the most common practices that most people follow where the data under the email attachments are kept for a longer period of time that increases the window of opportunity for a breach. Also, as most emails comprised of alpha numerical value there’s chances where one might send sensitive information to the wrong recipient that again makes it vulnerable.
2. Implement Data minimization and retention policies as soon as possible: Now the reason why I am saying this is because there’s a lot “Just in case” mindset hoarding around HR managers and other employees but the best practice is to avoid this mindset and collect only the data which are necessary for the task (for example, last 4 digits for the ID verification and not the full Aadhaar card or PAN card number). Additionally to set the data for auto deletion after onboarding process is completed or after certain mandatory or retention period. This is important to avoid any unethical or unwanted use of the data in future.
3. Training and awareness: There are many big tech stacks which have been failed just because they failed to train their people for the responsible use of the employees and company’s data. Some of the most crucial training that should be there to handle the use of the Aadhar and PAN card data can include:
Training HR teams with bite-sized videos and you can also create playbooks on handling sensitive documents.
Simulate common mistakes like forwarding Aadhaar via personal email and demonstrate it via videos or seminar or webinar that why this could be a risky practice thing to follow.
Build a data protection culture in your company from the very start through regular refreshers, newsletters, and onboarding security workshops.
You can provide training resources, presentation decks, and SOPs to help teams stay compliant without becoming paranoid.
Secure transmission and storage of data:
Securing the transmission and the storage of data super important when you collect sensitive employee info like their Aadhar and PAN card details and in such cases you need to make sure that nobody can steal or peak at them while they’re being sent or store anywhere. Here’s some best practices that you can follow to keep them safe while they are being sent:
Now think of this like you’re sending a secure and sealed package, now in this case you always need to send data over secure and encrypted channels (like HTTPS). And as mentioned earlier, avoid email or whatsapp to send any form of sensitive data instead you can use tools that encrypts the data automatically, so that hackers cannot intercept it during their transit. Additionally, you can use the one-time pins via the verified portals or platforms like Digilocker to collect the official documents.
Now once the data is transferred it becomes important to securely store them, here’s how you can securely store the sensitive data once it is received:
Now imagine locking that package in a vault, likewise store the documents in cloud systems that have strong security like AWS, Google cloud, or Microsoft Azure. Use the encryption at rest, which scrambles the data into the unreadable codes unless someone has the key to read it. Also, limit the people who can have access to open the vault that is, only your HR manager or compliance team should be able to access it.
Role-Based Access Control (RBAC) & Audit Trails:
When you are handling the employees sensitive information like Aadhar and PAN, not everyone in your company should be able to see it. Just like you would not give every employee a key to the CEO’s office. In the same way, HR managers and people should limit access based on the employees roles. That is exactly what Role-based access control (RBAC) does.
RBAC basically means you give people access only to the information that they need to do their job and nothing more than that. For example, an HR manager can view the Aadhar and PAN details for onboarding. A finance executive can only see PAN for tax related tasks but not the Aadhar card details. Likewise, a marketing intern sees none of it and not even by accident!
This practice of RBAC helps organizations to prevent any accidental data exposure, Intentional misuse as well as confusion about who can see that information within the organization. You can set this up in most systems like Google drives, HR software, or cloud storage platforms where you can assign them permissions to user roles, permissions like “Viewer, “Editor”, or “No access” etc.
Now an audit trails comes in the picture when you want to track who opened any sensitive file, when did they opened it, and what they did with it? that’s exactly where Audit trails come in. Audit trails keeps a log of every action like, who accessed a file, when they accessed it, whether they downloaded, edited, or shared it and from what location or device they used to access it.
Audit trails are like CCTV for your data so that you can spot any suspicious activity or investigate if something goes wrong.
Remote Device Security & DLP:
In a hybrid or remote work culture, your employees may be working from home, cafes, or even in any co-working spaces – often using laptops or phones to access info like Aadhar or PAN, payroll, and more. This makes it even harder to control the environment which means higher risk of data leaks, or misuse. That’s where Remote Device security and DLP (Data loss Prevention) comes in.
Remote Device Security makes sure that the laptops, phones, and other devices your team uses are safe and secure no matter where they are. Here’s how you can achieve it: Ask employees to use company managed devices, Install tools like MDM (Mobile Device Management) that lets you remotely lock a device or wipe them if it’s stolen or lost. RDS can even control what applications can be installed on the company managed device. It can even set security rules like screen locks or strong passwords. Just make sure that all the company managed devices or even other devices have up-to-date antivirus, firewalls, and encryption.
Please note that if someone’s device is not secure, even the best software won’t be able to protect you.
Now, what is data loss prevention? It is just like smart watchdog for your data. It watches how data is being used and stops risky behavior before it becomes a problem. Not even this but DLP can block someone from copying Aadhar and PAN numbers from on boarding file, stop any user from uploading PAN cards to google drive or Dropbox and prevent sending sensitive data via personal Gmail or social media apps.
DLP can be setup almost in every corporate tools like Microsoft 365, Google workspace, HR & Financial platforms and even in dedicated tools like Symantec DLP, Microsoft Purview, or Endpoint protector.
Remote Device Security is like locking the front door of the laptop, and DLP is like setting rules inside the house so no one can take valuables out without permission.
Vendor & SaaS Tool Vetting:
Imagine you have done everything right to protect your data, but the tool you use to collect the Aadhar card or PAN card gets hacked. You are still responsible. And this is why it is very crucial to vetting your tools and vendors that you’re using and it is not optional. As vetting protects your company from data breaches, staying legally complaint, and making sure your tools follow global security standards.
Here’s how you can vet a Vendor or SaaS tool, the first and foremost thing you should be looking for is their certifications like ISO 27001, SOC 2 and GDPR-compliant especially if dealing with global customers. This clearly means that your company takes data security very seriously and follows global best practices.
To proceed with vetting you should be asking about how your data is being stored or where do they store that data whether it is India, US, EU? Is it even encrypted at rest and in transit? Can you delete your data whenever you want?
Always review their privacy policy, as do they sell or share data with anyone else? or what happens if you stop using their services, do they still keep your data?
Don’t forget to include a data protection clause in the contract, as make sure your agreement includes: how they protect your data, what happens if there is a breach? and your right to audit or exit the respective vendor or tool.
make sure to run security tests as you or your IT partner can ask for or conduct VAPT (Vulnerability Assessment & penetration Testing) to see if their system can be easily hacked. Some tools also let you run a “Sandbox” trial to test features securely.
Vendor & SaaS tool vetting is like doing a background check before you give someone the keys to your house. If they don’t pass the test, they shouldn’t handle your sensitive employee data.
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