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SDF assessment template

An annual Data Protection Impact Assessment outline for Significant Data Fiduciaries under Rule 13, from the description of processing to sign-off. Customise it with counsel.

Updated 4 Nov 2026

Short answer

Rule 13 requires a Significant Data Fiduciary to carry out a Data Protection Impact Assessment and an audit once every twelve months and to furnish significant observations to the Board. This template structures the DPIA: description of processing, purposes, rights affected, risks, measures, residual risk, sign-off and significant observations. It is a sample, not legal advice; customise it with counsel and your independent data auditor.

An annual DPIA outline for Significant Data Fiduciaries under Rule 13. Fields ending in a colon are for you to fill in. Customise it with counsel.

Data Protection Impact Assessment: annual template for Significant Data Fiduciaries

1. Assessment details

Organisation (legal name):

Processing activity assessed:

Twelve-month period covered:

Date of this assessment:

Date of the previous assessment:

Prepared by (name and role):

2. Description of the processing

Personal data processed (itemise by class):

Data Principals affected (for example customers, children or employees) and approximate numbers:

Systems, data stores and processors involved:

Transfers outside India, if any:

Algorithmic software used on the personal data:

3. Purposes and ground

Specified purpose of the processing:

Ground relied on, consent (s.6) or a legitimate use (s.7, which one):

4. Rights of Data Principals affected

Rights this processing could affect (access, correction, completion, updating, erasure, grievance redressal, nomination):

How Data Principals exercise those rights for this processing:

5. Risks

Risks to the rights of Data Principals from this processing:

Likelihood and severity of each risk:

Risks from algorithmic software, and the due diligence done (Rule 13):

6. Measures

Security safeguards in place (Rule 6):

Measures to reduce each risk:

Owner and due date for each new measure:

7. Residual risk

Risk remaining after the measures:

Further action required:

Residual risk accepted by (name and role):

8. Significant observations for the Board

Rule 13 asks a Significant Data Fiduciary to furnish the significant observations from its DPIA and audit to the Data Protection Board.

Significant observations:

Date furnished to the Data Protection Board:

9. Sign-off

Data Protection Officer (name and date):

Independent data auditor's comments, if reviewed (name and date):

Approved by (Board of Directors or delegated authority, name and date):

What Rule 13 asks for

  • A DPIA and an audit once every twelve months
  • Significant observations from them furnished to the Data Protection Board
  • Due diligence that algorithmic software does not risk Data Principals' rights
  • Keeping personal data the Central Government specifies, on a committee's recommendation, and related traffic data within India

These sit on top of s.10(2)(c), which asks for a periodic DPIA and a periodic data audit. The Rule 13 explainer covers each duty.

How the template is laid out

Nine parts: assessment details, description of the processing, purposes and ground, rights affected, risks, measures, residual risk, significant observations for the Board, and sign-off.

Run one assessment for each major processing activity. Keep the evidence your independent data auditor will ask for next to it.

What the template does not do

Educational, not legal advice

This template is educational, not legal advice and not a certification. The layout is ours, not a prescribed format, and it does not decide whether you are an SDF: only a notification under s.10 does. Customise it with counsel.

How TruePrivacy helps

Impact assessments in TruePrivacy run DPIAs and PIAs from templates or blank. The SDF workspace starts yearly clocks for the DPIA, the data audit and algorithmic due diligence once you record the designation.

Records of processing supply the description of processing, synced from discovery. AI governance keeps the inventory of models and datasets your algorithmic due diligence starts from.

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
  • Digital Personal Data Protection (Removal of Difficulties) Order, 2026, S.O. 5458(E), Gazette of India, 6 October 2026

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

Questions, answered

Educational, not legal advice.

All DPDP FAQs
How often must an SDF carry out a DPIA?

Once every twelve months, together with an audit, under Rule 13.

What happens to the DPIA findings?

Rule 13 asks the Significant Data Fiduciary to furnish significant observations from the DPIA and audit to the Board.

Do companies that are not SDFs need a DPIA?

The DPIA duty in s.10(2)(c) and Rule 13 is a Significant Data Fiduciary duty. Other Data Fiduciaries can still use the template to understand risk.

Your DPDP plan, starting today

Core obligations for data fiduciaries begin on 13 May 2027.

13 May 2027

Core obligations begin