10 Questions That Reveal If You’re Truly DPDP Compliant. 

Most organizations think DPDP compliance is a checklist: a policy drafted, a banner added, a consent box checked. But documents do not prove compliance if they cannot be demonstrated on demand. 

The law exists to give the Data Principal the actual owner of the data, full control over how their information is collected, stored, used, shared, and ultimately deleted. They have rights to access, correction, objection, grievance redressal, and even nomination of heirs. 

The Digital Personal Data Protection Act (DPDP) has been around long enough; the grace period for 'figuring it out' is over. And here is the uncomfortable truth: many companies that believe they are compliant would fail a real audit in minutes. 

Where Delay Becomes Non-Compliance 

When something goes wrong, expectation is immediate accountability.  

Once you become aware of a breach, you must notify affected users and the Data Protection Board as soon as practicable. There is no safe investigation window. Delay itself can become non-compliance, and penalties can reach up to ₹250 crore. 

If the data use is risky, you are expected to evaluate the privacy impact before you start collecting it. That is the job of a Data Protection Impact Assessment (DPIA), done upfront, not after a breach teaches you why it mattered. 

The only reliable way to know your position is to test it. 

Below are 10 questions regulators, auditors, and incident investigators implicitly ask, and your answers will reveal whether you’re truly compliant… or just confidently exposed. 

Can You Prove and Manage Valid Consent Throughout Its Lifecycle? 

Consent is more than just a checkbox. It is evidence of a decision made by a person under specific terms. Users must be able to withdraw consent as easily as they gave it, including through registered Consent Managers acting on their behalf. 

Pass: You can show when consent was taken, what the user saw, what purpose they agreed to, and you can honor withdrawal requests without friction. 
Risk: You rely on a checkbox without stored consent records, versioned notices, or a clear withdrawal mechanism. 
Fix: Store consent receipts with timestamp, policy version, and purpose agreed to. Silence or pre-checked boxes are not defensible. 

Note: Consent Managers are independent, registered intermediaries under DPDP that provide a single place for Data Principals to view, give, or withdraw consent across multiple services. 

Do You Minimize Data Collection? 

Every extra field you collect becomes something you must protect, justify, and eventually delete. Most organizations do not notice over-collection because it builds slowly.  

A field added for marketing. Another for analytics. A legacy form nobody reviewed. 

Pass: You collect only the fields required for a defined purpose. Every attribute has a justification and a retention timeline. 
Risk: Forms include optional, legacy, or “nice to have” fields. Logs and backups accumulate extra personal data. 
Fix: Remove unused fields, sanitize logs, and map each data point to a business purpose and deletion schedule. 

Do You Know Exactly What Personal Data You Hold and Why? 

Many teams believe they know their data because they know their database. But personal data rarely lives in one place; it spreads across support tools, analytics platforms, exports, backups, test environments, and employee devices. 

Pass: You maintain a live data inventory mapped to purposes and systems. 
Risk: Different teams collect data independently, and nobody has a complete picture. 
Fix: Build a data map across apps, databases, endpoints, backups, and SaaS tools. Unknown data is unprotected data. 

Do Employees Have Access Only to the Data They Need? 

Breaches are often imagined as external attacks. In reality, they are over-permissioned access combined with curiosity or convenience. 

Pass: Access follows role-based or attribute-based control and is reviewed regularly. 
Risk: Shared accounts, inherited permissions, or old employee access still active. 
Fix: Enforce least privilege, remove standing access, and log internal data viewing. 

Do You Know Every Place Personal Data Leaves Your System? 

Data rarely leaks from databases. It leaves through people, tools, integrations, and routine workflows. 

Pass: You track exports, APIs, email transfers, integrations, and downloads. 
Risk: Data leaves through spreadsheets, support tools, messaging platforms, or shadow IT. 
Fix: Monitor outbound flows and restrict unsanctioned transfer channels. 

Is Personal Data Encrypted at Rest, In Transit, and In Use? 

Encryption is your last line of defense when everything else fails. Most breaches do not start with exposed backups, intercepted traffic, or legitimate access reading raw data. 

Pass: Data is encrypted in storage, over networks, and during processing through masking, tokenization, or secure computation. Keys are centrally managed, and access is logged. 
Risk: Only HTTPS is enabled, but databases, backups, logs, or internal services store readable personal data. 
Fix: Enforce end-to-end encryption, isolate key management, rotate keys regularly, and prevent systems from handling raw personal data unless strictly required. 

Are Your Vendors Safer Than Your Own Systems? 

Under the Act, your organization is the Data Fiduciary. Vendors and partners can process data on your behalf, but liability does not move with it. 

Pass: Vendors are assessed, contracted with data obligations, and continuously reviewed. 
Risk: You only trust certificates or procurement approval. 
Fix: Classify vendors by data sensitivity, require breach notification clauses, and verify controls periodically. 

Can You Detect Unauthorized Access, including Internal Misuse? 

Security tools often focus on malware while ignoring legitimate users behaving abnormally, for instance large exports at midnight, access outside the job role, and repeated viewing of sensitive records. 

Pass: Alerts exist for abnormal behavior such as bulk export, unusual hours, or role misuse. 
Risk: Monitoring only detects malware, not misuse by legitimate users. 
Fix: Implement behavioral monitoring and audit trails that cannot be altered. 

Do You Delete Data When Its Purpose Ends? 

Retention without deletion is simply delayed exposure. Inactive data still carries risk, especially when it sits in archives and backups long after its value disappears. 

Pass: Deletion is automated across primary storage, backups, and archives. 
Risk: Data is marked inactive but never removed, or only deleted manually on request. 
Fix: Implement lifecycle enforcement. Retention without enforced deletion becomes liability. 

If an Audit Happened Tomorrow, Could You Show Evidence? 

Compliance is not about whether controls exist, but whether they can be demonstrated immediately. If answering requires collecting screenshots and messaging different teams, compliance does not yet exist operationally. 

Pass: You can produce logs, consent records, access history, and deletion proof immediately. 
Risk: Evidence depends on collecting screenshots and asking multiple teams. 
Fix: Centralize compliance evidence. Compliance must be demonstrable, not reconstructable. 

Wrapping up 

This checklist is written for Data Fiduciaries, the organizations responsible for deciding why and how personal data is processed, not just storing it. On the other hand, Significant Data Fiduciaries (SDFs) handle large-scale or sensitive data and face stricter obligations under DPDP, including more frequent audits, detailed DPIAs, and tighter breach reporting.  

 If you hesitated on more than two questions, you are just assuming compliance at this point. 

A truly compliant organization does not scramble when an audit happens. It operates in a way where an audit changes nothing. Evidence already exists, access is already controlled, and data is already governed by purpose and lifecycle. 

India is rolling DPDP out in stages. The Rules arrived in November 2025, the Data Protection Board is active, Consent Managers come online by November 2026, and by May 2027 compliance stops being a roadmap and becomes an expectation. 

SQ1 helps organizations turn DPDP compliance from a checklist into operational certainty. Test your readiness today. 

FAQ 

1. What is the new Indian personal data protection law? 
   The Digital Personal Data Protection Act, gives individuals control over their data and sets rules for how organizations handle it. 

2. Who needs to comply with India’s Data Protection Act? 
   Any organization, Indian or foreign, that collects, processes, or stores personal data of individuals in India. 

3. Which companies offer DPDP services in India? 
   Several cybersecurity and compliance firms, including SQ1, provide DPDP readiness and implementation software and services.