DPDP Act 2023 + Rules 2025

The India compliance clock has already started.

Notified 14 November 2025. Penalties up to ₹250 crore for a single security-safeguard failure. Full compliance deadline: 13 May 2027. This page maps each DPDP obligation to the exact Cyfriq capability that addresses it.

₹250 Cr
Max penalty — failure to implement security safeguards
₹200 Cr
Max penalty — failure to notify breach to DPB & data principals
72 hours
Detailed breach report deadline to the Data Protection Board of India
13 May 2027
Full compliance deadline — DPDP Rules 2025 notified 14 Nov 2025
Coverage key

How to read this document.

Direct

Cyfriq directly addresses this obligation through built-in technical controls — no separate tool or custom configuration required.

Enabler

Cyfriq provides the tooling and evidence — but the customer must configure policies and operate the control to meet the obligation.

External

A legal, governance or consent obligation the customer must fulfil independently — Cyfriq provides supporting evidence only.

DPDP Act · section by section

Obligation-by-obligation coverage.

Section 8(5) + Rules 2025 · Penalty up to ₹250 Cr

Security safeguards

Encryption, access control, logging, breach detection.

Direct — Cyfriq covers this

What the law requires

Implement reasonable security safeguards — encryption at rest and in transit, access controls, audit logging and monitoring. Under DPDP Rules 2025 these are now prescriptive technical requirements: encryption/masking, tokenisation, access controls, audit logging and backup are explicitly listed. Organisations must be able to evidence these controls to the Data Protection Board.

How Cyfriq addresses this

  • AES-256 encryption at rest — separate encryption key per tenant stored in AWS KMS
  • TLS 1.3 encryption in transit — all data including agent-to-cloud communication
  • Role-based access control (RBAC) — users access only data relevant to their role
  • Immutable WORM audit log — every access, action and event recorded and tamper-proof
  • UEBA engine continuously monitors for anomalous access patterns and insider threats
  • MFA enforced on every login — TOTP, push, FIDO2 / YubiKey
  • Device trust — only registered healthy devices with valid certificates can access
Section 8(6) + Rules 2025 · Penalty up to ₹200 Cr

Personal data breach notification

Notify DPB & data principals without delay. 72-hour detailed report. Parallel 6-hour CERT-In notice.

Direct — Cyfriq covers this

What the law requires

Notify the Data Protection Board and all affected data principals immediately upon discovering a breach. Submit a detailed report within 72 hours covering nature, extent, timing, impact assessment, mitigation steps and cause. A parallel 6-hour CERT-In notification is also required.

How Cyfriq addresses this

  • Real-time breach detection via UEBA and DLP engine — alerts in seconds
  • Automated breach classification: data type, scope, affected users, timeline
  • Pre-built DPDP 72-hour breach report template — DPB-submission ready
  • Tamper-proof audit log provides complete forensic trail for regulators
  • Automated affected-user list for data principal breach notifications
  • SIEM integration supports parallel CERT-In 6-hour & DPB 72-hour workflows
Section 8 + Rules 2025

Access control & unauthorised processing prevention

Only authorised personnel may access personal data. Unauthorised processing is itself a breach.

Direct — Cyfriq covers this

What the law requires

Access controls are explicitly listed under Rules 2025 as required technical safeguards — not discretionary guidance. Organisations must implement and evidence controls that restrict personal data access to those with a legitimate, documented business need.

How Cyfriq addresses this

  • RBAC — personal data access strictly limited by user role and department
  • SSO and IdP enforce authentication before any data access is permitted
  • MFA required on every session — prevents credential-based unauthorised access
  • UEBA detects and alerts on access patterns inconsistent with normal behaviour
  • Device trust — unregistered or unhealthy devices denied at the IdP layer
  • Leaver workflow instantly revokes access across every connected system
Section 16

Cross-border data transfer controls

Personal data may only be transferred to countries not restricted by the Central Government.

Direct — Cyfriq covers this

What the law requires

Personal data of Indian data principals may only be transferred to countries not on the Central Government's restricted list. Organisations must have active technical controls preventing unauthorised transfer via email, file upload, cloud sync or any other digital channel.

How Cyfriq addresses this

  • Email DLP blocks transfer of personal data to domains in restricted countries
  • Browser extension blocks uploads of personal data to restricted-jurisdiction cloud services
  • Geo-blocking at IdP level — logins from restricted countries denied at authentication
  • All Cyfriq infrastructure on AWS India (ap-south-1) — customer data stays in India by default
  • Audit log records all data egress events with destination country for regulatory evidence
Section 6 + Rules 2025

Data minimisation & purpose limitation

Collect only what is necessary; use only for stated purpose.

Enabler — customer must configure

What the law requires

Only collect personal data that is necessary for the stated purpose. Do not use data beyond that purpose. Organisations must demonstrate active controls preventing over-collection and misuse across email, endpoints and web applications.

How Cyfriq enables this

  • DLP policies can block transmission of personal-data fields not required for a business process
  • Email DLP scans for PAN, Aadhaar, mobile numbers — blocks unauthorised sharing
  • Data classification engine labels documents by sensitivity and restricts access by role
  • Customer must define which data categories are in scope and configure policies accordingly
Section 8(7)

Storage limitation & data erasure

Delete personal data once the purpose is fulfilled. Passive indefinite storage is a violation.

Enabler — customer must configure

What the law requires

Personal data must be erased once the purpose for which it was collected is fulfilled, unless retention is required by law. Organisations must have active, configured retention policies with evidenced, auditable erasure workflows.

How Cyfriq enables this

  • Configurable data retention policies within the platform — set per data category
  • Automated user data purge on deactivation via SCIM leaver workflow
  • Audit log captures all erasure events as tamper-proof evidence for regulators
  • Customer must map their own data categories and set appropriate retention periods in Cyfriq policies
Sections 11–13 · 90-day response SLA

Data principal rights

Right to access, correct, erase, and grievance redressal.

Enabler — Cyfriq provides tooling

What the law requires

Individuals have the right to access, correct and erase their personal data, obtain grievance redressal within 90 days, and nominate another person to exercise rights. Under Rules 2025, organisations must provide a publicly available mechanism for submitting these requests.

How Cyfriq enables this

  • SCIM user-management enables data access & correction across all connected systems
  • Leaver and erasure workflows support right-to-erasure requests with full audit trail
  • Audit log enables access reports — what data was accessed, when, by whom
  • Customer must build a public Data Principal rights request portal — Cyfriq provides backend tooling only
  • Consumer-facing rights interface and 90-day SLA management are the customer's operational obligation
Section 10 · Significant Data Fiduciary

SDF obligations — DPO · DPIA · Independent audit

Applies to large-scale data processors designated by the Central Government.

Enabler — Cyfriq provides audit evidence

What the law requires

Organisations designated as Significant Data Fiduciaries must appoint a Data Protection Officer (DPO) based in India, conduct annual Data Protection Impact Assessments (DPIA), engage an independent data auditor, and periodically share significant observations with the Data Protection Board.

How Cyfriq enables this

  • Immutable audit log provides comprehensive evidence base for independent annual audits
  • Pre-built DPIA report template maps data flows, risks and Cyfriq control evidence
  • UEBA risk reports demonstrate active monitoring as evidence of "reasonable safeguards"
  • Data Protection Officer must be appointed by the customer organisation
  • Independent auditor engagement and DPB periodic reporting are the customer's own obligation
Sections 5, 6 + Rules 2025

Consent management

Free, specific, informed, unconditional and unambiguous consent before processing.

External — legal obligation on customer

What the law requires

Obtain free, specific, informed, unconditional and unambiguous consent before processing. Provide a clear privacy notice in English and all 22 languages of the 8th Schedule of the Constitution if required. Consent withdrawal must be as easy as giving consent.

How Cyfriq supports this

  • User onboarding portal can present privacy notices at first login for employee data processing
  • Audit log records consent acceptance with timestamp and user identifier as evidence
  • Customer's legal team must draft the privacy notice content — Cyfriq does not provide legal text
  • Consent Manager registration with the DPB is the customer's independent regulatory obligation
  • Consumer-facing consent withdrawal mechanism must be built by customer into their own product or portal
Financial exposure

DPDP penalty schedule & Cyfriq coverage.

ViolationMax penaltyCyfriq coverage
Failure to implement security safeguards₹250 croreDirect   AES-256, RBAC, MFA, WORM audit log, UEBA continuous monitoring
Failure to notify DPB & data principals of a personal data breach₹200 croreDirect   Real-time detection, pre-built 72-hour report, SIEM dual-notification
Violations relating to children's personal data processing₹200 croreEnabler   DLP & access controls configurable per data type & age category
Any other violation of the Act or Rules by a Data Fiduciary₹50 croreEnabler   Retention policies, erasure workflows, access reports, data classification
Breach of duty by a Data Principal₹10 000Not applicable — applies to individuals, not organisations
Roles under DPDP

Cyfriq as Data Processor. You as Data Fiduciary.

CYFRIQ — DATA PROCESSOR
Our commitments to you
  • Processes personal data only as instructed by the customer
  • DPDP-aligned Data Processing Agreement covering all activities
  • SOC 2 Type II + ISO 27001 — evidence of "reasonable safeguards"
  • Customer notified within 6 hours of a suspected breach
  • All data on AWS India (ap-south-1) — residency by default
  • Sub-processor list disclosed and maintained — changes pre-notified
CUSTOMER — DATA FIDUCIARY
Your independent obligations
  • Draft and publish privacy notices (22 scheduled languages if required)
  • Obtain and manage valid consent from data principals before processing
  • Appoint a DPO based in India if designated as Significant Data Fiduciary
  • Build a public Data Principal rights request mechanism
  • Conduct annual DPIA and engage independent data auditor (if SDF)
  • Register as Consent Manager with DPB if operating a consent-management platform
Implementation timeline

DPDP Rules 2025 — phased compliance schedule.

Phase 1 · November 2025 — already in force

Foundations live

  • Data Protection Board of India constituted & operational
  • Core definitions and basic duties operative
  • Grievance redressal mechanisms live
  • Transparency obligations active
  • Begin Cyfriq deployment and agent rollout now
Phase 2 · November 2026 — consent regime

Consent framework

  • Consent Manager registration opens with DPB
  • Consent governance and oversight framework live
  • Implement consent workflows in your products
  • Verify Cyfriq onboarding portal privacy notices in place
  • Complete DPIA for significant processing activities
Phase 3 · 13 May 2027 — full compliance

Everything enforceable

  • Security safeguards — fully operational & independently auditable
  • 72-hour breach reporting workflow fully operational
  • Data retention & erasure policies configured and active
  • Cross-border transfer controls enforced and evidenced
  • SDF obligations complete — DPO, DPIA, audit engaged
  • All penalties fully enforceable from this date
Value proposition

The fastest path to DPDP compliance readiness.

Every Indian organisation is now on an 18-month countdown to full DPDP compliance with ₹250 crore penalty exposure for security-safeguard failures alone.

Cyfriq directly addresses the two highest-penalty obligations — security safeguards (₹250 Cr) and breach notification (₹200 Cr) — out of the box, on day one of deployment. No other point solution in the market covers both obligations simultaneously while also providing IAM, SSO and insider-threat detection in the same platform. Cyfriq is the fastest path to DPDP compliance readiness for any enterprise — regardless of which email provider or licence tier they currently use.