Digital Personal Data
Protection (DPDP) Compliance
Practical DPDP Compliance & Audit for Indian Businesses.
Move beyond generic privacy policies. We build governance frameworks, offer Virtual DPO support, and provide independent data audits that defend your business against penalties.
The Problem – Why Now?
The DPDP Act 2023 is Not Just a Policy Update.
It’s a shift to strict regulatory enforcement. Generic GDPR templates won’t work. If your business collects digital data—names, numbers, KYC, employee records—you are now accountable.
- Financial Risk: Penalties up to ₹250 Crore per instance.
- Operational Risk: Mandatory reporting of data breaches to the Data Protection Board.
- Reputational Risk: Loss of customer trust if you cannot fulfil data rights (access/erasure).
- Personal Liability: Senior management is directly accountable for compliance.
Who Needs This?
Does DPDP Apply to You?
If you use digital tools to run your business, the answer is likely YES.
- Startups & SaaS: Processing user data, logins, and analytics.
- E-Commerce & Retail: Handling customer orders, payments, and marketing lists.
- Professional Firms (CA/Legal/Consulting): Managing sensitive client financial and tax data.
- Healthcare & Labs: Processing patient records and diagnostic reports.
- Manufacturing & B2B: Using ERP/HRMS for employee and vendor data.
How We Help – Our Service Model
Governance First. Audit Ready. Practical Implementation.
We don’t just hand over legal documents. We act as your Compliance Architects—designing the controls, workflows, and evidence you actually need to demonstrate DPDP compliance for Indian startups, SaaS companies, growing SMEs and larger organisations that are or may become Significant Data Fiduciaries.
Data Discovery & Scoping
- We start by discovering where personal data actually resides across your tools—webforms, product databases, CRMs, HR/payroll, email, shared drives, and SaaS platforms.
- Distinguish personal vs non‑personal data, production vs test/sandbox copies, and identify “crown jewels” (high‑risk datasets like KYC, financial, health).
- Deliverable: A DPDP‑focused Data Discovery Snapshot that becomes the foundation for mapping, safeguards, and audit evidence.
Gap Assessment & Roadmap
- We assess your current data flows, notices, consent flows, contracts, and security practices against DPDP requirements.
- Identify high‑risk gaps in consent, user rights, vendor controls, and technical safeguards that could attract penalties.
- Deliverable: A clear, prioritised DPDP Action Plan with “Quick Wins”, “Foundational Controls”, and “Audit‑Critical Items”.
Data Inventory, Mapping & Systems View
- You can’t protect what you can’t see. We map where your data actually lives—CRM, HRMS, email, shared drives, SaaS tools, cloud—so you have a single view of personal data.
- Classify data by purpose, legal basis, and retention, and link it to actual systems and owners (not just a spreadsheet).
- Deliverable: A DPDP Data Inventory Register- a single view of what personal data you hold, why you hold it, where it sits, who you share it with, and how long you keep it. You can reuse for audits, Virtual DPO reviews, and future certifications.
Consent and Privacy Notices
- Redrafting privacy notices and consent language in plain English or regional language where applicable, aligned with how your website, app or other platforms actually work.
- We also help your tech team or vendors set up clear, trackable consent flows (banners, check‑boxes, preference centres, unsubscribe options)
- Deliverable: DPDP‑compliant notice templates, practical consent flow suggestions, and Consent Management SOPs.
Rights, Grievances & Case Handling
- We design the operational workflow and system touchpoints for access, correction, and erasure requests—who does what, in which tool, and in what timeline.
- Set up your Grievance Redressal mechanism, logs, and escalation matrix so you can demonstrate compliance to the Board and the Data Protection Board if required.
- Deliverable: Rights Request SOP, Grievance Handling Process, and Tracking Log format that can be plugged into your existing tools.
Vendor, Processor & Cloud Risk
- Your responsibility doesn’t end at your own servers. We review key vendors—HR/payroll, marketing agencies, background verification, SaaS tools, cloud providers—to check DPDP alignment.
- Strengthen contracts and onboarding with DPDP‑aligned clauses on security, breach‑notification, sub‑processors, and data localisation where needed.
- Deliverable: Vendor Due‑Diligence Checklist, sample Data Processing Agreement clauses, and a simple vendor‑risk heatmap.
Reasonable Security Safeguards & Breach Readiness
- We translate “reasonable security safeguards” into simple actions for startups and SMEs – who can see data, how access is given, and how basic protections (MFA, device hygiene, secure cloud settings) on your cloud and devices are set.
- We also give you a clear plan for what to do if there is a breach – who responds, how to contain it, and when to inform users or regulators.
- For companies that already have security teams and tools, we focus on reviewing and testing whether existing safeguards actually meet DPDP expectations – access controls, encryption/masking, logging and monitoring, backups, and incident‑response playbooks.
- Deliverable: A practical “reasonable security safeguards” baseline for your organisation and a DPDP‑aligned breach‑response playbook you can rely on with your Board, auditors, or the regulator.
Virtual DPO, Governance & Independent Audit
- For startups and SMEs, we act as your Virtual DPO—providing ongoing advisory, oversight on grievances and rights requests, and periodic reviews of DPDP controls and security safeguards.
- For Significant Data Fiduciaries, we perform mandatory independent data audits and support your internal DPO with evidence gathering, control testing, and Board‑level reporting.
- Deliverable: Periodic Virtual DPO reports, governance dashboards for founders/Boards, and independent audit reports that withstand regulatory scrutiny.
Why Choose J S R T & CO?
Why Trust Us with Your Data Governance?
As a CA firm, internal controls, risk, and audit are our core strengths. We approach DPDP as a business process, not just a legal theory.
We combine Legal + Finance + Tech. We partner with specialized cybersecurity firms for technical validation.
We don’t over-engineer. We build right-sized solutions for Indian businesses—from startups to mid-sized enterprises.
Special Services for Significant Data Fiduciaries
Mandatory Audit & Assurance for SDFs: Does DPDP Apply to You?
Our SDF Audit Services:
Is your organization classified as a “Significant Data Fiduciary” based on volume or sensitivity? The DPDP Act mandates independent data audits and periodic assessments.
- Independent Data Audits: We conduct the mandatory annual audit of your compliance framework, verifying consent records, grievance logs, and technical safeguards.
- DPIA Validation: We review and validate your Data Protection Impact Assessments (DPIAs) to ensure they meet Board standards.
- Board Reporting: We help your DPO prepare the required audit reports for the Data Protection Board of India.
Why J S R T & CO for SDF Audits?
- Independence: As a CA firm, we bring the required independence and rigor to data audits.
- Integrated Assurance: We audit data controls alongside IT and financial controls for a holistic view of risk.
Addressing Common Doubts — FAQs
1. How similar is DPDP work to what companies do for GDPR?
Many of the building blocks are very similar – keeping a data inventory, defining clear purposes, managing consent and notices, handling access/erasure requests, reviewing vendors, and putting “reasonable security safeguards” in place.
DPDP is written for India and is not a copy‑paste of GDPR, but if you follow a structured DPDP programme, you are already doing a lot of the groundwork that global privacy programmes also rely on.
I am a small firm. Does this apply to me?
Yes. There is no exemption for small businesses in the Act currently. If you process digital personal data, you must comply.
Can I just copy a privacy policy from the internet?
No. DPDP requires specific details in your notice (e.g., grievance officer contact, rights description) that generic templates miss. Invalid notice = Invalid consent.
What is a "Significant Data Fiduciary"?
A classification for companies with high data volume or risk (like fintech/health). We help you assess if you fall into this category.
My data is stored in the cloud (AWS/Google). Am I safe?
Not automatically. Cloud providers secure the infrastructure, but you are responsible for the data you put there (access controls, encryption, deletion). Under DPDP, you (the Data Fiduciary) are liable for breaches, not just AWS.
Do I need to hire a full-time Data Protection Officer (DPO)?
It depends. If you are a “Significant Data Fiduciary” (high volume/risk), yes. For most SMEs, you need a Grievance Officer (mandatory). We can help you define this role or provide Virtual DPO advisory support.
How is this different from my annual financial audit?
Financial audits look at money. DPDP audits look at personal data flows and governance controls. However, the discipline is similar—we apply the same rigor of internal controls and risk assessment to your data that we do to your finances.