What Counts as a Reasonable Security Safeguard under DPDP? and The 2026 DPDP Audit Checklist: 50 Things Auditors Will Ask For · Content Duplication Tool

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Common questions about reasonable security safeguards under DPDP

DPDP Rule 6 points to retaining relevant security logs and records for at least one year as part of reasonable safeguards, which sets a minimum rather than a maximum. CERT-In Directions, sectoral regulations, contractual obligations with customers, and your own forensic and internal investigation needs may justify or require longer retention for certain logs. At the same time, DPDP’s broader principles on storage limitation and data minimisation apply, so indefinite retention of all logs is unlikely to be appropriate. A practical approach is to define retention periods by log type, balancing regulatory requirements, business needs, and the sensitivity of any personal data those logs may contain, and to document the rationale so you can explain it if asked. The Digital Personal Data Protection Act, 2023 (No. 22 of 2023) - Ministry of Law and Justice, Government of India India Digital Personal Data Protection Act, 2023 (DPDP Act) and Digital Personal Data Protection Rules, 2025 – Overview - EY India Overview and Key Highlights of The Digital Personal Data Protection (DPDP) Rules, 2025 - RSM India Guidelines on Information Security Practices for Government Entities - Indian Computer Emergency Response Team (CERT-In), MeitY Cyber Security Framework in Banks - Reserve Bank of India Identify, Protect, Detect, Respond and Recover: The NIST Cybersecurity Framework - National Institute of Standards and Technology (NIST)

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Common questions about DPDP audit readiness

External expertise is most valuable where DPDP leaves room for interpretation or where your organisation faces heightened scrutiny. Typical triggers include assessing whether you are likely to be designated a Significant Data Fiduciary, designing cross-border data strategies as government notifications evolve, reconciling DPDP with sectoral rules from regulators such as the RBI or SEBI, and planning responses to serious incidents that may require notification to the Data Protection Board and affected Data Principals. Specialist privacy auditors can also pressure-test your controls against emerging industry practice and provide independent reports for boards or major customers. For procurement, it is useful to anticipate these engagements early for high-value deals or renewals where counterparties are likely to increase their DPDP expectations. [4] The Digital Personal Data Protection Act, 2023 - Government of India – India Code Digital Personal Data Protection Rules, 2025 - Ministry of Electronics and Information Technology, Government of India Explanatory Note to Digital Personal Data Protection Rules, 2025 - Ministry of Electronics and Information Technology, Government of India Digital Personal Data Protection Bill, 2023 – Legislative Brief and Summary - PRS Legislative Research Monthly Policy Review – January 2025 (DPDP Rule-making) - PRS Legislative Research Guidelines on Digital Lending – Reserve Bank of India - Reserve Bank of India

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Common questions about reasonable security safeguards under DPDP

Common questions about DPDP audit readiness