The Digital Personal Data Protection Act, 2023 (DPDPA 2023) has surprised many organizations, while the Ministry of Electronics and Information Technology (MeitY) has made its intention clear—to ensure the security and privacy of Data Principals.
Many companies are currently declaring themselves self-proclaimed DPDP 2023 Phase-1 compliant, whereas the processes and procedures governing their digital assets do not align with such claims.
Considering the recent observations of the Honorable Supreme Court of India on the Right to Privacy, and the growing concerns among stakeholders, it is evident that governments, the judiciary, and regulatory bodies are increasingly focused on preventing digital data misuse at multiple levels.
The concern becomes even more critical when data misuse begins to intersect with national security considerations.
In my opinion, based on the clauses laid out in DPDPA 2023, it would take only a few targeted queries to determine whether an organization’s claim of Phase-1, Phase-2, or Phase-3 compliance is genuine.
Merely integrating with a Consent Management Platform (CMP) or developing an internal consent platform does not constitute compliance. True compliance requires refinement of the entire data ecosystem, including:
Structured data governance
Hierarchical access control
Continuous monitoring and audit mechanisms
Transparent consent lifecycle management
Organizations must understand that DPDPA compliance is not a technical checkbox exercise but a comprehensive governance framework.
If you require guidance, audit support, or implementation assistance for complying with DPDPA 2023, feel free to reach out.
