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Vendor due diligence under DPDP

Under DPDP, your vendors' processing is your responsibility. Due diligence before signing, and again on a schedule, keeps that risk visible.

Updated 4 Nov 2026 · 4 min read

Short answer

You remain responsible for processing your Data Processors carry out for you (s.8(1)), you may engage them only under a valid contract (s.8(2)), and Rule 6 requires security terms in those contracts. Before onboarding a SaaS or IT vendor, establish its role, where it processes data, its sub-processors, its security safeguards and how quickly it will tell you about a breach. Tier vendors by risk, and reassess on a set cadence and whenever their service changes.

Why DPDP makes vendors your problem

Section 8(1) keeps you responsible for processing by your processors, and s.8(2) requires a valid contract. If a vendor has a breach, you must intimate the Board and each affected Data Principal (s.8(6), Rule 7), and your clock runs from when you become aware.

Vendors you do not know about are the biggest gap. A SaaS tool signed up on a company card may hold customer or employee data with no contract at all, and a breach there is still yours to report.

Questionnaire themes

ThemeQuestions to askWhy
RoleDo you process our data only on our instructions, or for your own purposes too?Processor or fiduciary changes the contract (s.8(2))
Data and purposeWhich personal data do you receive, and what do you use it for?Purpose limits and access requests (s.11)
LocationWhere is data stored, processed and accessed, including support and backups?s.16, Rule 15, sector rules
Sub-processorsWho are your sub-processors, where are they, and how do you tell us about changes?Keeps the chain under contract
SecurityDo you use encryption, masking or tokens, access control, logging and monitoring, and backups? How long do you keep logs?Rule 6
BreachHow soon will you tell us after becoming aware, and what will you share?Rule 7
ErasureCan you stop processing and erase on our instruction, and confirm it?s.6(6), s.8(7)
Rights supportCan you find, export, correct and delete one person's data on request?s.11, s.12

Tier vendors by risk

TierTypical vendor (sample)DiligenceReassess
HighCore database host, payments or KYC provider, HRIS and payrollFull questionnaire, evidence review, contract covering every clause themeEvery year and on change
MediumCRM, support desk, marketing email toolFull questionnaire, contract with security and breach termsEvery two years and on change
LowTools holding only business contact dataShort questionnaire and standard termsAt renewal

This is a sample scheme. Set tiers by the volume of personal data, whether it includes children's or financial data, and whether the data leaves India. Re-tier a vendor when it starts receiving new kinds of data or moves processing abroad.

Steps to run due diligence

Run these steps before signing any new vendor. For existing vendors, start with the reassessment step and work through them by tier, high first.

  1. 01Find every vendor

    Combine procurement, finance and single sign-on records with a discovery scan, so unknown SaaS tools show up.

  2. 02Screen for personal data

    Set aside vendors that never touch personal data, and keep the rest.

  3. 03Tier

    Assign a tier using the sample scheme or your own.

  4. 04Send the questionnaire

    Ask the questions for the tier, and ask for evidence behind high-tier answers.

  5. 05Decide

    Approve, approve with conditions, or reject, and record the reason.

  6. 06Contract

    Sign a processor contract using the processor contract checklist.

  7. 07Reassess

    Repeat on the tier's cadence, and whenever the vendor changes location, sub-processors or service.

Due diligence checklist

  • Vendor list reconciled with finance and single sign-on
  • Role confirmed: processor or fiduciary
  • Locations and sub-processors recorded
  • Rule 6 security answers reviewed
  • Commitment to breach notice without delay
  • Erasure and rights support confirmed
  • Contract signed before data flows
  • Next review date set

How TruePrivacy helps

Vendors and processors keeps vendor records with risk levels, sends assessments through a vendor portal link, and offers question templates, including one asking processors to report breaches without delay. Contracts (DPAs) are tracked alongside.

System discovery in data discovery lists the systems your organisation uses, each marked detected, reviewed or connected, so shadow SaaS becomes visible. Cross-border transfers warns when a vendor matches a country on your restriction list. Related template: the processor addendum.

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
Do we need to assess every vendor under DPDP?

Every vendor that processes personal data for you, because you remain responsible for its processing (s.8(1)). Scale the depth of review to the risk.

How often should vendors be reassessed?

Set a cadence by tier, such as yearly for high-risk vendors, and reassess whenever a vendor changes location, sub-processors or service.

What breach notice should we require from vendors?

Notice without delay after the vendor becomes aware, because your Rule 7 duties run from when you become aware.

Is a vendor questionnaire enough?

No. You also need a valid contract with security terms (s.8(2), Rule 6).

Your DPDP plan, starting today

Core obligations for data fiduciaries begin on 13 May 2027.

13 May 2027

Core obligations begin