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Who TruePrivacy helps with DPDP

DPDP duties sit with the organisation, but the work lands on people. Start with your company's shape or with your own role.

Updated 4 Nov 2026

Short answer

The DPDP Act, 2023 places its duties on the Data Fiduciary as an organisation, whatever its size, and core obligations under the DPDP Rules, 2025 begin on 13 May 2027. Each team owns part of the work: legal owns notices and contracts (Rule 3, s.8(2)), security owns safeguards and breach response (Rule 6, Rule 7), product owns consent flows (s.6) and HR owns employee data (s.7(i)). Pick your company size or role below.

What changes with company size

A startup or MSME needs a lean programme: know its data, fix notices, sign processor contracts and be ready for a breach. An enterprise adds many entities and brands, a DPO operating model, and readiness in case it is notified as a Significant Data Fiduciary under s.10. A GCC first works out which of its processing the s.17(1)(d) exemption covers.

What changes with role

RoleOwnsStarts with
DPO or privacy leadThe programme and its evidenceRule 9 contact, grievance period, Rule 13 if notified
CISOSecurity safeguards and breach responseRule 6 controls, Rule 7 timings
FounderDates, owner and budget13 May 2027 plan
LegalNotices, contracts, legitimate-use recordsRule 3, s.8(2), s.6(10)
ProductConsent and children's flowss.6, s.9, Rule 10
HREmployee and candidate datas.7(i), HR vendor contracts

Sources

  • Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023)
  • Digital Personal Data Protection Rules, 2025, G.S.R. 846(E), 13 November 2025

Updated 4 Nov 2026. Educational information, not legal advice.

Questions, answered

Educational, not legal advice.

All DPDP FAQs
Does DPDP apply to small companies?

Yes. The duties fall on every Data Fiduciary. Do not assume an exemption; check with counsel whether a specific one covers you.

Who should own DPDP inside a company?

One named owner, with legal, security, product and HR each owning their part. A DPO is mandatory only for Significant Data Fiduciaries (s.10(2)(a)), but every fiduciary publishes a contact under Rule 9.

When do the main duties start?

Core obligations begin on 13 May 2027. Consent Manager registration under Rule 4 starts on 13 November 2026.

Your DPDP plan, starting today

Core obligations for data fiduciaries begin on 13 May 2027.

13 May 2027

Core obligations begin