Data Protection Impact Assessment (DPIA)
Plain English Translation
Under Section 10(2)(c)(i), if you are designated as a Significant Data Fiduciary, you must conduct a periodic Data Protection Impact Assessment. This isn't just a paperwork exercise; it is a mandatory process to identify and facilitate risk management DPDP challenges before they affect users. The assessment must describe the rights of Data Principals, the purpose of processing, and specifically evaluate any potential harm to those rights. Conducting a thorough privacy impact assessment India ensures that your data processing risks India are managed proactively rather than reacting to a breach later.
Technical Implementation
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Required Actions (startup)
- Create a manual checklist for evaluating privacy risks before launching new features.
- Document the purpose of processing for all data sets.
- Review risks annually with the leadership team.
Required Actions (scaleup)
- Adopt a formal DPIA template integrated into the project management tool.
- Conduct assessments whenever a new vendor or data type is introduced.
- Train product owners on identifying data processing risks India.
It is a process comprising a description of the rights of Data Principals, the purpose of processing, and the assessment and management of risk to those rights (Section 10(2)(c)(i)).
It is required periodically for Significant Data Fiduciaries (Section 10(2)(c)(i)). Specific triggers or frequency may be prescribed by rules.
The Significant Data Fiduciary is responsible for undertaking the assessment (Section 10(2)). It often involves the Data Protection Officer and relevant business units.
It must cover a description of Data Principal rights, the purpose of processing, and the assessment and management of risk to those rights (Section 10(2)(c)(i)).
No, Section 10(2) specifically imposes this obligation only on Significant Data Fiduciaries notified by the Central Government.
Section 10(2)(c)(i) states it must be 'periodic'. Future rules may specify the exact frequency, often expected to be annual or upon significant changes.
The fiduciary must manage the risk to the rights of the Data Principals (Section 10(2)(c)(i)). This implies implementing mitigation measures to reduce the risk.
The Act does not explicitly mandate public publication, but the findings may need to be shared with the Board or Auditor as part of the periodic audit (Section 10(2)(c)).
"undertake the following other measures, namely:— (i) periodic Data Protection Impact Assessment, which shall be a process comprising a description of the rights of Data Principals and the purpose of processing of their personal data, assessment and management of the risk to the rights of the Data Principals, and such other matters regarding such process as may be prescribed;"
| Version | Date | Author | Description |
|---|---|---|---|
| 1.0.0 | 2026-02-08 | WatchDog Security GRC Wiki Team | Initial publication from DPDP Workbook |
