DPDPA Execution with TurtleShield: Six steps towards your compliance journey

Sameer Ahirrao -

The Ministry of Electronics and Information Technology (MeitY) released the draft Digital Personal Data Protection (DPDP) Rules for public consultation. This is a major milestone in advancing data privacy regulations in India. To ensure compliance, organizations must implement robust mechanisms to safeguard data and empower data principals. Here are six crucial steps through which you can execute DPDPA:

1. Conduct PIA/DPIA/TIA (Risk Assessments)

Performing Privacy Impact Assessments (PIA), Data Protection Impact Assessments (DPIA), and Transfer Impact Assessments (TIA) is a critical step towards:

  • Identification of Applications and Processes Handling PII: Determine where Personally Identifiable Information (PII) resides within your organization.
  • Assessment of Compliance for Data Transfers: Ensure that data-sharing activities comply with legal requirements for transfers outside India.

These assessments help in identifying potential risks and compliance gaps, setting the foundation for robust data protection practices.

Ardent Solution: The TurtleShield PA (Privacy Automation) automates and streamlines privacy-related processes and tasks. Conducting PIAs and DPIAs enhances privacy practices, ensures India’s DPDPA compliance with applicable privacy laws, and also protects sensitive information.

2. Discover PII (Personal Data Bill of Materials)

Understanding the data your organization processes is essential and, to achieve this the following steps should be undertaken

  • Data Discovery and Mapping: Locate and map PII across all systems and processes.
  • Build a Data Bill of Materials (DBoM): Catalog all data points collected and processed.
  • Record Processing Activities (RoPA): Maintain comprehensive records of data processing activities, ensuring visibility of your organization’s data ecosystem.

Ardent Solution: Our Innovative tool "TurtleShield DD (Data Discovery)" addresses these challenges by discovering hard-to-find datasets at scale, enabling quick actions, and reducing compliance costs. It locates and categorizes data based on regulatory requirements like DPDPA, ensuring companies maintain compliance, secure sensitive information, and minimize data breach risks.

3. Implement Data Principal Rights Management

Under DPDPA, data principals have specific rights, including the right to access, erasure, and correction. To meet these obligations, you must:

  • Create a Secure Data Portal: Enable data principals to submit requests seamlessly.
  • Empower Privacy Teams: Integrate tools like data discovery modules to facilitate the fulfillment of rights requests efficiently.

A transparent and responsive rights management system builds trust and ensures compliance.

Ardent Solution: TurtleShield DSAR streamlines the Data Subject Access Request (DSAR) process, ensuring efficient compliance with DPDP Act. It offers a centralized portal for intake, automated data discovery, and secure response delivery.

4. Establish a Centralized Consent Management System

Consent is the cornerstone of DPDPA compliance. Create a consent mechanism by:

  • Centralized Consent Collection and Management: Create a unified system for gathering, storing, verifying, and revoking consent.
  • Managing Preferences and Notices: Offer clear privacy notices and easy-to-use preference management options.
  • Integration with Consent Managers: Ensure your system integrates with multiple consent managers to enhance flexibility.

Ardent Solution: TurtleShield CM (Consent Management) automates required user privacy notices, the gathering and management of consent/opt-out privacy preferences, and the operational honoring of preferences by both internal and downstream third-party data sharers.

5. Enforce Storage Limitation Requirements

Storage limitations is a key data protection principle which minimizes data retention risks. To comply, you must:

  • Set Data Retention Rules: Define clear deletion schedules based on the classification of data fiduciaries, such as e-commerce, social media, or gaming platforms.
  • Enable Automated Deletion: Implement tools to enforce these schedules efficiently, ensuring timely data erasure.

According to the draft DPDP Rules, e-commerce entities and social media companies with over 2 crore users in India, or gaming platforms with over 50 lakh registered users, must delete inactive user data within three years.

Ardent Solution: TurtleShield DM (Data Minimization) helps you reduce the data and focus on enterprise-centric data. It can provide you detailed insights to get rid of non-essential data, reducing cost of security and storage and building confidence of business owners and data custodians.

6. Implement Data Breach Management and Notification

Timely detection and notification of data breaches are essential to mitigate any harm to personal data. Steps that you must include to be proactive during such a crisis, are:

  • Automating Internal Breach Management: Establish workflows to identify and manage breaches.
  • Enabling Notifications: Notify affected data principals and the Data Protection Board within stipulated timeframes.
  • Meeting the Timelines: Notify data principals and the Data Protection Board immediately upon discovery of a breach. Provide detailed information to the Board within 72 hours. Retain logs to detect and investigate breaches for at least one year.

Follow DPDPA Timelines

Ensure adherence to the timelines prescribed under the DPDPA:

  • Data Deletion Notifications: Notify data principals at least 48 hours prior to data erasure, providing them time to take action.
  • Retention Rules: Maintain consent records for seven years. Retain logs for one year to detect and investigate unauthorized access.

By following these steps, organizations can not only achieve compliance but also build a privacy-first culture that fosters trust among stakeholders.

About Ardent Privacy

Ardent’s mission is to help enterprises implement meaningful security and privacy programs aligned to their business mission, building trust and protecting data assets. Ardent’s technology “TurtleShield” is a holistic software platform that empowers enterprise security, legal, and data teams to implement and manage data privacy within the organizations with rapid data asset visibility and actions to enable privacy compliance, govern AI risk, meaningful data protection, and reduce cost of compliance and data breaches. Our unique and patented ML/AI-powered technology helps organizations comply with evolving privacy and AI regulations and accelerates adoption of AI technologies. Ardent offers a low code platform to automate Privacy & AI governance, rapid discovery of data assets and consent management with regional focus for global regulations.