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DPDP Act

DPDP Breach Response Playbook

An India-specific incident response playbook covering the DPDP Act's notify-everything breach regime — data principal notices, the 72-hour detailed report to the Data Protection Board, and coordinating with CERT-In's parallel 6-hour reporting obligations.

26 min read
1

What Counts as a Breach Under the DPDP Act

This section provides comprehensive guidance on what counts as a breach under the dpdp act as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.

Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.

Practical action

Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.

2

Detection, Triage & Classification

This section provides comprehensive guidance on detection, triage & classification as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.

Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.

Practical action

Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.

3

Notifying Affected Data Principals

This section provides comprehensive guidance on notifying affected data principals as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.

Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.

Practical action

Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.

4

The 72-Hour Report to the DPBI

This section provides comprehensive guidance on the 72-hour report to the dpbi as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.

Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.

Practical action

Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.

5

CERT-In Reporting in Parallel

This section provides comprehensive guidance on cert-in reporting in parallel as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.

Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.

Practical action

Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.

6

Processor & Vendor Escalation Duties

This section provides comprehensive guidance on processor & vendor escalation duties as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.

Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.

Practical action

Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.

7

Post-Incident Review & Evidence Trail

This section provides comprehensive guidance on post-incident review & evidence trail as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.

Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.

Practical action

Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.

In this guide

  1. 1What Counts as a Breach Under the DPDP Act
  2. 2Detection, Triage & Classification
  3. 3Notifying Affected Data Principals
  4. 4The 72-Hour Report to the DPBI
  5. 5CERT-In Reporting in Parallel
  6. 6Processor & Vendor Escalation Duties
  7. 7Post-Incident Review & Evidence Trail

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