Data & compliance
DPDP 2023 posture, data residency, consent, no-PII stance, certifications.
Regulatory posture
| Framework | Status |
|---|---|
| DPDP Act, 2023 (India) | Compliant. Swiggy is the Data Fiduciary; the MCP layer exposes only data already covered by Swiggy's existing consent framework. |
| IT Rules (India), 2011 (Sensitive Personal Data) | Compliant. |
| GDPR | Best-effort for EU users - not a primary target market. Mail builders@swiggy.in if you need a GDPR DPA. |
| CCPA/CPRA | Same as GDPR - best-effort. |
Who is the Data Fiduciary
Under DPDP 2023, Swiggy is the Data Fiduciary for all user data accessed through MCP. Your integration acts as a Data Processor operating within the scope Swiggy permits.
What that means in practice:
- Users consent to Swiggy's processing of their data when they sign up for Swiggy; the MCP layer does not expand that consent scope.
- Your integration can only use Swiggy-originated data to serve the user's immediate task (e.g. placing an order). Analytics, training data, ad targeting require separate, explicit consent on your side.
- Any data-subject request (access, correction, erasure) concerning Swiggy-originated data is handled through the Swiggy app - direct users there.
Data residency
| Concern | Region |
|---|---|
| Primary compute | AWS Mumbai (ap-south-1) |
| Primary data stores | India |
| Secondary / failover | AWS Singapore (ap-southeast-1) - active-passive |
| User-facing traffic | India-edge CDN |
No user data leaves the India/Singapore region boundary. Swiggy does not route MCP requests through US or EU regions.
If your platform processes MCP responses outside India (e.g. your LLM inference runs in US-East), you must:
- Have a signed Data Processing Agreement with Swiggy before production.
- Maintain Standard Contractual Clauses (SCCs) or equivalent cross-border transfer mechanisms.
- Minimize fields crossing the border - summarise locally when possible, don't ship full order history to inference.
Mail builders@swiggy.in for a template DPA.
What flows through tool calls
A tool call may carry:
- User identifiers (opaque to you; no raw phone / email / name returned by tools).
- Tool arguments - addresses, cart items, coupon codes.
- Tool responses - restaurant data, menu items, order status, delivery partner info.
Treat all of this as PII under DPDP. Audit your logging accordingly.
What you must do
If you store or process Swiggy tool responses on your side:
- Do not persist user PII longer than needed to serve the current session - unless you have your own lawful basis and user consent.
- Do not use Swiggy-originated data for analytics, advertising, or model training without explicit user consent and a DPA.
- Log only what you need for debugging. Store the session id (for correlation with Swiggy-side logs), not full request/response bodies in plaintext.
- Honour deletion requests - if a user deletes their Swiggy account or requests deletion from you, any derived data on your side must also be deleted.
- Hash user identifiers at rest unless a specific lawful basis requires plaintext.
Encryption
- In transit: TLS 1.2+ everywhere (HSTS enforced).
- At rest: AES-256 on all persistent stores.
- Tokens: signed JWT with short lifetimes.
Audit logs
Every tool call produces an audit log entry on Swiggy's side keyed by session id. Retained 90 days. Available on lawful request (DPA / subpoena / regulatory order).
Data subject rights
Swiggy honours DPDP-mandated rights directly through the Swiggy app:
- Access - users request a copy of their data in-app.
- Correction - users update profile, addresses, preferences.
- Erasure - deleting the Swiggy account deletes associated MCP-accessible data within 30 days.
If you receive a DSR on your side involving Swiggy-originated data, direct the user to the Swiggy app. Coordinate with builders@swiggy.in if the request is complex.
Certifications
Available on request under NDA:
- SOC 2 Type II report (Swiggy's underlying infrastructure).
- ISO 27001 certification.
- PCI DSS for payment-adjacent systems. (MCP itself doesn't touch card data; order flows resolve to Swiggy's own checkout.)
Security contact
Security issues go to security@swiggy.in, not builders. Standard responsible-disclosure window: 90 days.
Signed manifests (roadmap)
The MCP ecosystem is converging on a signed-manifest pattern to attest tool integrity. We'll adopt it once the spec stabilises (targeting v1.2). Until then:
- Tool schemas are published on this site (see reference) and are auto-generated from source - no human drift.
- Any schema mismatch in your client should be treated as a security-relevant event; report to security@swiggy.in.