India's Digital Personal Data Protection Rules were notified on 13 November 2025 and apply in phases: the Consent Manager framework from 13 November 2026, and the core compliance provisions from 13 May 2027, according to Mondaq. The Data Protection Board can impose penalties of up to Rs 250 crore per instance of non-compliance.
Most employers think about customer data first. But training systems collect personal data too, and VR training can collect a lot of it.
What VR and simulator training can record
- Identity: name, employee ID, unit or department.
- Performance: scores, errors, reaction times, pass or fail.
- Behaviour: how a trainee drove, flew or responded to a fault.
- Device data: some headsets can capture head and hand movement or eye tracking.
Performance records can affect careers, so they deserve the same care as other personal data.
Questions to ask about your training systems
- What is collected, and is all of it needed for the training purpose?
- Where is it stored? On your premises, with the vendor, or in a cloud outside India?
- Who can see it? Instructors, managers, the vendor?
- How long is it kept, and when is it deleted?
- Does the software send data outside your network, for example usage telemetry?
- How would a breach be detected and reported?
Practical steps before May 2027
- Map the personal data each training system collects.
- Update notices so trainees know what is recorded and why.
- Set retention periods for training records.
- Prefer systems that can keep data on your own infrastructure.
- Include training vendors in your data processing agreements.
How our systems handle training data
Our training systems, including the VRMMDS driving simulator and VRMDFS drone simulator, are designed to be deployed on-premise and can run air-gapped, so training data can stay inside your facility. See our technology and security approach.
This article is a summary, not legal advice. Confirm your obligations with your data protection advisers. Questions about how a simulator handles data? Ask for a security briefing.