Read MoreSoftware teams in India are now being asked a question that earlier sat mostly with legal and compliance teams: “Where is our personal data, why do we have it, and can we prove we are protecting it?” The Digital Personal Data Protection (DPDP) Act, 2023 turns that question into an engineering workstream with artefacts, controls, and measurable response timelines.
A useful way to approach DPDP readiness is to treat it like a product quality programme. Build a register of what you process, bake consent and user rights into flows, harden systems, and keep evidence. When done well, this reduces breach risk, support escalations, and last-minute audit panic.
DPDP, translated for software teams
The DPDP Act focuses on personal data, processed in digital form. Many obligations land directly on systems and delivery processes, not just policy documents. Software teams typically own:
- How consent is captured, stored, and enforced
- How notices are displayed (and versioned)
- How a user can access, correct, or delete their data
- How retention and deletion are automated
- How breaches are detected, contained, and reported
- How processors and vendors are integrated safely
If your product has user accounts, analytics, customer support tooling, payment flows, KYC, HR modules, IoT telemetry, or even simple contact forms, treat DPDP as a build requirement.
A phase-wise compliance checklist that teams can execute
A checklist works best when it is time-boxed and mapped to deliverables. Many organisations run DPDP readiness in four phases, with a continuous review loop.
After you set up ownership (product, engineering, security, legal, support), use this sequence:
- Discovery and assessment
- Design and policy updates
- Implementation across app, infra, and operations
- Audit readiness and ongoing monitoring
Teams that already run ISO-aligned processes (quality and security) usually find this structure familiar.
What to build and what to file: the core evidence set
DPDP compliance is hard to defend without records. Even with strong security, you need to show what you did, when, and why.
The artefacts below are the most common “ask” during internal reviews and customer questionnaires:
- Data inventory listing fields, sources, purpose, storage location, recipients, retention
- Data-flow diagrams across apps, services, third parties, and environments
- Processing register of activities and lawful basis (often consent-led)
- Consent logs with time, purpose, notice version, and method of capture
- Privacy notices (current and historical versions)
- Retention schedule and proof of deletion jobs or workflows
- Data principal request records (access, correction, erasure, nomination, withdrawal)
- Incident response plan and breach drill outputs
- Security test outputs (vulnerability scans, penetration testing summaries)
- Training completion records and access review evidence
- Audit reports and remediation tracking
DPDP delivery plan at a glance (table)
| Phase | Typical timeline | Engineering outcomes | Evidence to retain | Primary owners |
|---|---|---|---|---|
| Discovery and assessment | 0 to 3 months | Data map, flow diagrams, classification, child-data check | Data inventory, processing register draft, gap report | Product + Eng + Security |
| Design and policy | 4 to 6 months | Updated notice and consent UX, rights workflow design, retention logic design | Notice drafts, consent specs, retention schedule, vendor addenda drafts | Product + Legal + Eng |
| Implementation | 7 to 12 months | Consent service, withdrawal flow, rights portal/API, logging, encryption, access control | Consent receipts, logs, runbooks, test reports, training records | Eng + Security + Ops |
| Audit and certification readiness | 13 months onwards | Evidence-driven controls, audit trails, periodic checks | Internal audit reports, remediation tickets, third-party audit reports (if applicable) | Compliance + Security + Eng |
Phase 1: discovery and assessment (data mapping and gap analysis)
Start with an inventory, not assumptions. Most teams underestimate how much personal data exists in logs, analytics events, support tools, and exports.
A practical discovery sprint usually includes application owners walking through:
- Collection points: UI forms, SDKs, API endpoints, imports
- Storage: primary DBs, caches, search indexes, data lakes, backups
- Sharing: payment gateways, SMS and email providers, CRM, helpdesk, fraud tools
- Access paths: admin panels, support access, data exports, BI dashboards
- Special cases: minors’ data, biometric/health/financial signals, profiling
The main output is a gap report: what the Act expects versus what exists today, with a remediation roadmap and priorities.
Phase 2: design and policy updates (notice, consent, retention, rights)
DPDP compliance breaks quickly when UX and backend disagree. If the UI says “we use data for X” but the backend also uses it for Y, you carry risk.
Design updates usually focus on four items:
- Privacy notice, written to be clear, layered, and usable on mobile
- Consent screens that are purpose-specific and revocable
- Rights handling flows, with identity verification and ticketing
- Retention and deletion logic, including how backups are handled
Before building, ensure product and engineering agree on “purpose” definitions. Purpose sprawl is a common failure point.
After that paragraph, use a compact checklist that teams can pin to the sprint board:
- Notice content: purpose, categories, retention, sharing, grievance or contact route
- Consent capture: affirmative action, purpose-wise capture, versioning of notice text
- Consent withdrawal: as easy as giving consent, immediate enforcement in processing paths
- Retention schedule: per data category, business need, legal need, deletion method
- Rights workflow: access, correction, erasure, nomination, withdrawal; identity checks
Phase 3: implementation (controls in code, infra, and operations)
Implementation is where “policy” becomes “proof”. Treat privacy features like security features: reviewed, tested, and monitored.
A strong build-out usually includes:
- A consent store (or service) that answers: what did this user consent to, for which purpose, at what time, under which notice version
- Centralised logging and audit trails for access to personal data, admin actions, and data changes
- A rights-management portal or API, connected to data stores and support tooling
- Automated retention jobs that delete or anonymise data past retention
- Role-based access control, least privilege, MFA for privileged access
- Encryption in transit and at rest, including backups and exports
- Security testing gates in CI/CD (SAST, dependency scanning) plus periodic pen tests
After that paragraph, keep one technical controls list that mixes short phrases and two-part bullets:
- TLS everywhere
- MFA for privileged access
- Encryption at rest: databases, object storage, backups, portable exports
- Access control: RBAC, least privilege, quarterly access reviews
- Audit logging: consent events, admin reads, bulk exports, retention deletions
- Vulnerability management: patch SLAs, scanning reports, remediation tracking
Rights requests: build it like a product feature, not a mailbox
DPDP gives data principals rights to access, correction, erasure, nomination, and consent withdrawal. The Act also expects timely responses (commonly interpreted as within 90 days for many request types).
Software teams can reduce operational load by making rights handling self-serve where feasible:
- Access: “Download my data” export with scoped fields and a secure link expiry
- Correction: editable profile fields with change logs
- Erasure: deletion request flow with status, exceptions (legal retention), and confirmation
- Nomination: a structured nomination capture and a verification workflow
- Withdrawal: per-purpose toggles and immediate effect on downstream processing
Do not skip identity verification. Many breaches begin as support impersonation.
Incident response and breach notification: what needs to be ready before day one
A breach workflow cannot be written during a breach. DPDP expects notification to the Data Protection Board “as soon as practicable” after discovery, and users must be informed in the prescribed manner when required. Draft rules and common practice often target an internal 72-hour notification SLA for serious incidents.
For software teams, readiness means:
- Clear severity definitions (what qualifies as “serious” inside your organisation)
- On-call ownership for security incidents
- Log sources connected to alerting (application logs, WAF, IAM, database audit logs)
- A forensics-friendly approach (time sync, immutable logs, restricted access)
- Notification templates prepared in plain language
- A recordkeeping method for all breach actions and communications
Run breach drills. Treat them like fire drills, not paperwork.
Vendor and processor controls: what engineering must verify
Most products depend on processors: cloud hosting, messaging, analytics, support desks, payment gateways, KYC providers. DPDP risk often sits in misconfigured integrations or uncontrolled data sharing.
Engineering can contribute by maintaining a vendor inventory linked to the data-flow diagram, then validating:
- What personal data is shared, and why
- Where it is stored and for how long
- What security controls exist (encryption, access controls, audit logs)
- How deletion and withdrawal are honoured downstream
- How you receive breach notifications from that vendor
Contract clauses matter, yet system behaviour matters more. If a vendor contract says “delete on request” but your integration cannot trigger deletion, the operational outcome is weak.
Bake DPDP into the SDLC: a practical workflow
DPDP “privacy by design” becomes real when it shows up in user stories, architecture reviews, and testing. A workable SDLC integration looks like:
- Requirements: tag stories that process personal data, define purpose and retention, define consent needs
- Design review: approve data flow, define logging, define access control model, define failure modes
- Coding: enforce purpose checks, validate inputs, reduce data in logs, secure secrets
- Testing: verify withdrawal, deletion, export, and retention jobs end-to-end
- Release: confirm notice and consent versioning, monitor for unusual data access patterns
- Post-release: review logs, close remediation items, refresh the processing register
After that paragraph, one short list of common gaps helps teams self-audit during sprint reviews:
- Consent stored but not enforced in downstream jobs
- Deletion only removes UI access, not backend copies
- Logs capturing personal data by default
- Shared admin accounts and weak audit trails
- Retention schedule written, deletion not automated
How an ISO-certified IT partner typically supports DPDP execution
Atrity Info Solutions Private Limited works across software engineering and cybersecurity, with ISO 9001 and ISO 27001 certified practices. For many organisations, that combination helps because DPDP requires both engineering change and security safeguards, backed by evidence.
Support in a DPDP programme usually falls into three practical buckets:
- Engineering delivery: consent services, rights portals, retention automation, audit logging
- Security hardening: encryption, MFA, DLP, secure network design, monitoring, testing
- Evidence readiness: documentation packs that combine technical proof (scan reports, configurations) with process proof (runbooks, access reviews, incident drills)
When selecting any partner, keep the scope clear. DPDP has legal interpretation pieces and operational pieces; software teams benefit most when delivery focuses on turning requirements into working features, controls, and audit-friendly records.
A simple cadence that keeps you audit-ready
DPDP work is not a one-time project. Products change, vendors change, and data flows change. A light but consistent cadence prevents drift:
- Quarterly: refresh data inventory, review vendor list, check retention jobs, sample rights request tickets
- After major releases: update data-flow diagrams and the processing register, re-run privacy test cases
- Annually: re-train staff, run a breach drill, run an internal audit, plan remediation
This cadence also helps during enterprise sales cycles, where customers ask for privacy posture evidence long before any regulator does.