What is Aadhaar Masking?
Aadhaar and its regulations are governed by UIDAI. And as per UIDAI, Aadhaar masking refers to covering the first eight digits of Aadhaar number – in physical or digital form. More precisely, Aadhaar masking refers to concealing the first 8 digits of the Aadhaar Number captured in Application forms and the Aadhaar Card copies (physical or digital) captured as part of proof of identity along with the Application.
What are the circulars pertaining to Aadhaar Masking?
You can refer to the following regulations with regards to Aadhaar masking.
UIDAI regulation on Aadhaar Masking dated 23 October 2018: Ordinance Aadhaar Amendment: F.No.13012/171/2018/Legal/UIDAI/114
RBI regulation on Aadhaar Masking: Master Direction – Know Your Customer (KYC) Direction, 2016 (Updated 29 May 2019): RBI/DBR/2015-16/18,Master Direction DBR.AML.BC.No.81/14.01.001/2015-16 AND Amendment to Master Direction (MD) on KYC: RBI/2018-19/190,DBR.AML.BC.No.39/14.01.001/2018-19
IRDAI regulation on Aadhaar Masking dated 29 January 2019: Allowing of Aadhaar Card as one of the acceptable documents for KYC- under certain conditions: Ref: IRDAI/SDD/Cl R/MISC/020/01/2019
SEBI regulation on Adhaar Masking dated 24 April 2020: Clarification on Know Your Client (KYC) Process andUse of Technology for KYC: Ref: SEBI/HO/MIRSD/DOP/CIR/P/202
When do I have to mask Aadhaar numbers?
As per regulations, you will have to mask Aadhaar preferably at the point of capture and certainly before storing them permanently in your downstream systems and databases.
Do I have to mask Aadhaar number in video?
Can I store unmasked Aadhaar number in my database?
No. You as per regulations you cannot store the full Aadhaar Number in your downstream systems and databases. However, if you have an Aadhaar Vault system, you may store the full Aadhaar Number in your vault and then use a surrogate number in your downstream numbers. This would be same as the solution adopted by the industry to store Credit card numbers.
Do I have to mask historical Aadhaar images?
Yes. Every Aadhaar Card captured thus far need to be masked irrespective of the age of the application.
Can I use technology to mask Aadhaar numbers?
Yes. The good news is that the technology has advanced in recognizing the 12-digit Aadhaar numbers and therefore are able to do detect and mask Aadhaar numbers from images and videos accurately. In the master KYC directive published by RBI, the regulator recommends the use of AI technologies for such tasks.
I am not a regulated entity; do I still have to mask Aadhaar Numbers?
Yes. Regardless of the industry you are in, you will have to mask/redact Aadhaar numbers as per current regulations. For instance, even if you are just a small start-up taking Aadhaar as proof of identity from employers, the same needs to be masked before filing and storage.
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