DPDP Assessment

The Digital Personal Data Protection Act (DPDPA), 2023 represents India's first comprehensive data protection law, operationalized through the Digital Personal Data Protection Rules, 2025 notified in November 2025. This framework establishes a citizen-centric approach to personal data protection, balancing individual rights with lawful data processing needs.

The DPDP framework rests on seven core principles: consent and transparency, purpose limitation, data minimization, accuracy, storage limitation, security safeguards, and accountability. The Act applies to organizations processing digital personal data within India, as well as entities outside India offering goods or services to Indian residents.

Any organization that processes digital personal data of individuals in India must comply with the DPDPA requirements. To achieve and demonstrate compliance, organizations need to undertake the following steps:

  • Gap Assessment against DPDPA Requirements: Comprehensive evaluation of current data processing practices against the mandatory obligations under the Act and Rules.
  • Implementation of Technical and Organizational Measures: Deployment of appropriate security safeguards, consent management mechanisms, and privacy frameworks.
  • Independent Assessment and Validation: Third-party assessment to validate compliance with DPDPA provisions and readiness for enforcement.

The DPDP Rules, 2025 implement a phased compliance timeline over 12-18 months, requiring organizations to progressively align their data processing activities with the Act's requirements. As a trusted compliance partner, QRC will help you navigate the complexities of DPDPA, ensuring your organization meets all regulatory obligations while building trust with customers and stakeholders.

Assessment Approach

RBI PSS Audit

Business Understanding

Understanding your data ecosystem, business processes, and current data handling practices to define the assessment scope accurately.

RBI PSS Audit

Assessment Scope Finalization

Detailed questionnaire shared with your teams to identify data fiduciaries, data processors, and data processing activities within scope.

RBI PSS Audit

Initial Readiness Assessment

Conduct preliminary gap analysis against DPDPA requirements to identify priority areas and establish baseline compliance status.

RBI PSS Audit

Data Mapping and Classification

Identify and document all digital personal data processing activities, data flows, storage locations, and third-party data sharing arrangements.

RBI PSS Audit

Compliance Validation

Assess implementation of DPDPA obligations including consent mechanisms, data principal rights, security safeguards, and purpose limitation.

Consent Management Review

Evaluate consent collection, management, and withdrawal mechanisms for compliance with DPDPA requirements for free, specific, informed, and unambiguous consent.

Policy and Documentation Review

Review and validate privacy notices, data processing policies, data retention policies, and breach response procedures against DPDPA mandates.

RBI PSS Audit

Remediation Support

Provide actionable recommendations and support for addressing identified gaps and achieving full DPDPA compliance.

frequently asked questions

Organizations should begin with a comprehensive gap assessment, implement consent management systems, update privacy policies and notices, establish data breach response procedures, map all data processing activities, deploy technical security measures, and train employees on data privacy requirements. 

A personal data breach is defined as any unauthorized or accidental compromise of personal data\'s confidentiality, integrity, or availability. Data Fiduciaries must notify the Board and affected individuals without delay, and submit a detailed report to the Board within 72 hours. 

A Consent Manager is a person registered with the Data Protection Board who acts as a single point of contact, enabling Data Principals to give, manage, review, and withdraw consent through an accessible, transparent, and interoperable platform. 

The DPDPA  permits  cross-border data transfers to all countries unless specifically restricted by the Central Government through notification. This  represents  a significant liberalization compared to earlier draft proposals. 

Significant Data Fiduciaries (SDFs) are organizations  designated  by the government based on volume and sensitivity of data processed. SDFs have enhanced obligations including appointing a Data Protection Officer based in India, conducting Data Protection Impact Assessments, and periodic audits.   

The Data Protection Board can impose penalties up to INR 250 crore for failure to implement reasonable security safeguards to prevent personal data breaches, and up to INR 50 crore for other violations of the Act. 

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