A complete DPDP Act compliance programme, from consent management and Data Principal rights to breach notification and SDF obligations, covering duties for Data Fiduciaries processing digital personal data in India.
The DPDP Act 2023 applies to every Data Fiduciary processing digital personal data of individuals in India, with penalties up to ₹250 crore for non-compliance. Beyond penalties, DPDP compliance prepares your organisation for enforcement and demonstrates data protection maturity to customers and regulators.
Identify Data Fiduciary obligations; determine SDF classification requiring DPO appointment and periodic DPIA.
Review current data practices against DPDP Act obligations; identify gaps and prioritise remediation before enforcement.
Evaluate SDF classification criteria based on volume, sensitivity, and Central Government notification thresholds.
Map all digital personal data collected, processing purposes, data principals, and retention periods per DPDP Act requirements.
Audit consent collection and management practices against Section 6 requirements for granularity and revocability.
Assess international transfers against DPDP Act provisions and government notifications on permissible transfer destinations.
Design and implement granular, revocable consent mechanisms per Section 6; build clear purpose statements for each processing activity.
Deploy Data Principal rights workflows for access, correction, erasure, and grievance redressal; set defined response timelines and escalation paths.
Support SDF DPO appointment or operate as interim DPO; manage compliance oversight, regulatory liaison, and grievance redressal.
Build DPB and CERT-In notification procedures meeting the DPDP Act breach reporting obligations to the Data Protection Board.
Draft DPDP-compliant privacy notices covering all required disclosures: processing purposes, Data Principal rights, and contact details.
Draft Data Processor contracts ensuring DPDP Act compliance; embed processing restrictions and breach notification duties.
Conduct periodic reviews of processing activities, consent records, and Data Principal rights processes as DPDP rules are notified.
Deliver role-based DPDP training for legal, HR, product, and engineering teams; include annual refreshers and scenario-based exercises.
Monitor Central Government notifications, DPB guidance, and rule updates affecting DPDP compliance obligations and timelines.
Conduct periodic DPIAs for Significant Data Fiduciaries per DPDP Act provisions and government notification.
Maintain consent records and manage revocations; update Data Principal rights workflows as processing evolves and new rules take effect.
Support Data Protection Board investigations, grievance redressal escalations, and formal regulatory enquiries across DPDP jurisdictions.
Any organisation processing digital personal data of individuals in India regardless of size or sector is a Data Fiduciary under the DPDP Act.
Multinationals and SaaS companies with Indian customers or employees processing their data must comply with the DPDP Act regardless of where they are headquartered.
Large platforms designated as SDFs face additional obligations: mandatory DPO, periodic DPIA, data localisation, and government-notified data audits.
A structured six-phase process from initial gap assessment and Data Fiduciary classification through to ongoing regulatory monitoring and compliance maintenance.
Assess current data practices against DPDP Act obligations and classify your Data Fiduciary status including SDF determination.
Build consent management system compliant with Section 6 and Data Principal rights response workflows with defined timelines and escalation paths.
Draft privacy notices, processing agreements, breach procedures, and DPO charter if required, aligned with DPDP Act requirements.
Support DPO appointment for SDFs or operate as interim DPO, and establish DPB and CERT-In breach notification procedures with response templates.
Assess SDF-specific data localisation requirements for sensitive personal data and review cross-border transfer mechanisms against government notifications.
Monitor regulatory developments, update programme as rules are notified by the Central Government, and maintain consent and rights processes as processing evolves.