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Digital Personal Data Protection Act, 2023

Your data register is now a legal register.

Every company, society, trust, LLP and professional practice that touches an Indian's personal data is a Data Fiduciary under the DPDP Act — whether or not it ever meant to be. JurisTatva builds the notices, consent architecture, registers, policies and SOPs that turn that exposure into a documented, defensible compliance file.

0
Mandatory Instruments
0h
Board Breach Notification
₹0 Cr
Maximum Schedule Penalty
0d
Rights-Request Ceiling
Data Fiduciary Data Principal Consent Manager Data Mapping Breach SOP Consent Notices Vendor DPAs Privacy Policy Retention Policy Data Protection Board Data Fiduciary Data Principal Consent Manager Data Mapping Breach SOP Consent Notices Vendor DPAs Privacy Policy Retention Policy Data Protection Board
Applicability · Sec. 3 read with Sec. 2(i)

The Act doesn't ask what kind of entity you are.

It asks whether you determine the purpose and means of processing digital personal data in India. A "person" under Sec. 2(s) includes companies, societies, trusts, LLPs, sole proprietors and unincorporated associations alike — for-profit or not.

✓
Employee & HR Records
Payroll, PF/ESI, appraisals and contact data of staff and consultants — Sec. 5's notice duty applies to every Data Principal, including employees.
✓
Members, Donors & Investors
Governing body, shareholder, donor and funder contact details — a not-for-profit or society structure gives no exemption.
✓
Website, App & Event Data
Visitors, newsletter subscribers, webinar and training participants — every intake channel is a processing activity.
✓
Vendor & Client Contacts
Any personal data shared with, or received from, processors and sub-processors under a service contract.
If any of the above sits in your systems today, you are already a Data Fiduciary under Chapter II of the Act — the only open question is how much of your compliance file exists in writing.
The JurisTatva DPDP Framework

44 mandatory instruments, organised into 7 layers.

Resolutions, registers, notices, consent forms, policies, agreements and SOPs — every "shall"-type obligation in the Act mapped to a specific deliverable, not a slide.

L1
Board Resolutions & Governance
Adoption resolutions and role allocation for accountability
L2
Data-Mapping Registers
Every flow: collection point, purpose, retention need
L3
Statutory Notices (×8)
The itemised notices owed to every Data Principal
L4
Consent Architecture & Logs
Consent-cum-notice forms and auditable consent records
L5
Policies
Master privacy, retention & breach policies
L6
Agreements
Vendor DPAs that make processing enforceable
L7
Standard Operating Procedures
Breach, grievance & rights-request SOPs on the clock
Registers & Notices
Data mapping, consent logs, breach registers and the 8 statutory notices owed to every Data Principal.
Policies & Agreements
Master privacy policy, retention & breach policies, and the vendor DPAs that make processing enforceable.
Standard Operating Procedures
Step-by-step SOPs that keep every 72-hour, 48-hour and 90-day statutory clock auditable.
Explore the full framework →
Engagement Method

From data map to board adoption, in four stages.

Each stage closes with a reviewable deliverable, not a status update — so your compliance file grows in fixed, verifiable increments.

01
Diagnostic & Data Mapping
Inventory every personal-data flow — collection point, purpose, retention need — and confirm your Data Fiduciary obligations under Chapter II.
Deliverable · Data-flow register
02
Notices & Consent Architecture
Draft the itemised notice-cum-consent framework, website and employee notices, and the rights & grievance intake forms.
Deliverable · Notice + consent set
03
Policies, Agreements & SOPs
Master privacy policy, retention & breach policies, vendor DPAs, and the step-by-step SOPs that keep every deadline auditable.
Deliverable · Policy & SOP pack
04
Board Adoption & Handover
Consolidate review comments, finalise every instrument, and walk your team through the resolution for formal adoption.
Deliverable · Adopted compliance file
Schedule of Penalties

Non-compliance is priced in crores, not notices.

The Data Protection Board of India can impose these amounts directly — without displacing a Data Principal's right to separately pursue civil remedies.

₹250 Cr
Failure to take reasonable security safeguards to prevent a data breach.
₹200 Cr
Failure to notify the Board and affected Data Principals of a breach.
₹200 Cr
Non-compliance with obligations relating to children's personal data.
₹50 Cr
Non-compliance with any other duty of the Data Fiduciary or Principal.
72h
Detailed breach report generally expected to the Data Protection Board once the fiduciary becomes aware.
48h
Prior notice owed to a Data Principal before scheduled erasure of their personal data.
90d
Outer ceiling entities generally build around to resolve a rights request or grievance.

Penalty bands reflect the Schedule to the DPDP Act, 2023. Timelines follow prevailing practice under the Act and Rules and should be confirmed for your specific facts.

Find out exactly which of the 44 instruments you're missing.

A short diagnostic call maps your data flows against the DPDP checklist and tells you precisely where your exposure sits — before we quote a single rupee of fee.

Frequently Asked

DPDP Act, 2023 — the questions people actually ask.

Any person — including a company, LLP, society, trust or sole proprietor — that determines the purpose and means of processing digital personal data in India is a Data Fiduciary under Section 2(i), regardless of whether it is for-profit or not-for-profit.

A Data Fiduciary must notify the Data Protection Board of India and each affected Data Principal without delay, with a detailed report generally expected within 72 hours of becoming aware of the breach.

The Data Protection Board can impose penalties of up to ₹250 crore for failing to take reasonable security safeguards, with separate bands of up to ₹200 crore (breach notification and children's data) and up to ₹50 crore for other categories of non-compliance.

Entities generally build their grievance-redressal SOP around a 90-day outer limit for resolving a Data Principal's rights request or grievance.

A defensible compliance file typically includes a data-mapping register, consent notices and logs, a master privacy policy, retention and breach policies, vendor DPAs, and SOPs for breach, grievance and rights-request handling — JurisTatva's framework organises 44 such instruments across 7 layers.

Yes. A "person" under Section 2(s) includes companies, societies, trusts, LLPs, sole proprietors and unincorporated associations alike. A not-for-profit or society structure gives no exemption where the entity processes digital personal data in India.

Still have questions? Talk to our experts →

Map your exposure before we scope a fee.

A diagnostic call tells you precisely which of the 44 instruments apply to your data flows.

44
Mandatory Instruments
7
Compliance Layers
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