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The Challenge of Data Protection in a Digital World

The Digital Personal Data Protection Act (DPDPA) is here. It’s changing how organizations handle data, shifting power to individuals, and making CISOs rethink their strategies. This isn’t just another regulation—it’s a fundamental shift in data security, privacy, and compliance.

Key Questions Explored:

• How does DPDPA differ from other data protection laws like GDPR and PDPA?
• What are the key challenges organizations face in implementing DPDPA?
• What steps must CISOs take to manage consent, data retention, and breach response effectively?
• How can organizations navigate third-party risk management under DPDPA?
• What role does AI play in data protection, and how can it be integrated within a compliance framework?

Understanding DPDPA – The Basics for CISOs

At its core, DPDPA is about accountability. Organizations must protect personal data, respect user rights, and implement strong security measures. Key principles include:

• Digital-Only Scope: Unlike GDPR, which covers all personal data, DPDPA focuses strictly on digital data.
• Controller vs. Processor Roles: Unlike GDPR, DPDPA places more accountability on data controllers rather than processors.
• Cross-Border Data Transfers: Unlike GDPR’s structured mechanisms, DPDPA simply prohibits transfers to blacklisted nations without providing clear transfer mechanisms.
• Age of Consent Differences: GDPR allows for a consent age of 13-16 years, whereas DPDPA sets it at 18.
• Breach Notification Requirements: GDPR uses a risk-based approach, while DPDPA mandates full disclosure in all cases.

For CISOs, the question isn’t whether DPDPA applies—it’s how to implement it effectively.

The CISO’s Action Plan for DPDPA Compliance

1. Data Discovery & Classification – Know What You Have

You can’t protect what you don’t know. The first step is understanding what personal data your organization collects, processes, and stores.

• Identify Sensitive Data: Map out where personal data resides within the organization.
• Classify Data by Risk Level: High-risk data (financial, health, biometric) needs stricter security.
• Create a Data Inventory: A central repository helps track data sources and ownership.

2. Consent Management – Building Trust with Users

Under DPDPA, consent isn’t just a checkbox—it’s a commitment. Organizations need:

• Clear Opt-in Mechanisms: Users should actively consent to data collection.
• Granular Control: Users must manage their preferences, such as opting out of specific data uses.
• Audit Trails: Maintain logs of consent requests, approvals, and withdrawals.

Stay Ahead of Data Protection Challenges

Data privacy isn’t just about compliance—it’s about building trust. Engaging with experts and leveraging best practices can help businesses stay ahead of evolving regulations. Join the cybersecurity conversation at CISO Platform (Invite Only Platform for CISOs).

3. Security Controls – Fortifying Data Protection

Security isn’t optional under DPDPA. CISOs must implement strong technical controls, including:

• Encryption: Protect data at rest and in transit.
• Access Controls: Role-based access ensures only authorized users handle sensitive data.
• Anomaly Detection: AI-driven monitoring detects suspicious activities.
• Incident Response Plans: Clear strategies for breach detection, reporting, and containment.

4. Third-Party Risk Management – Closing the Supply Chain Gaps

Vendors and service providers process personal data, creating compliance risks. CISOs must:

• Conduct Vendor Assessments: Ensure third parties follow DPDPA requirements.
• Define Clear Contracts: Establish security expectations in agreements.
• Monitor Vendor Compliance: Continuous audits prevent data leaks from weak links.

5. Data Retention & Disposal – When to Let Go

Holding onto data indefinitely is a risk. Organizations must:

• Define Retention Policies: Align with legal and operational requirements.
• Automate Data Deletion: Set expiration timelines for unnecessary data.
• Ensure Secure Disposal: Use certified destruction methods for sensitive records.

DPDPA is not just a regulation—it’s a shift toward responsible data management. For CISOs, compliance means balancing security, transparency, and user rights. The best organizations won’t just meet DPDPA requirements—they’ll set new standards for data privacy.

Be Proactive. Be Secure. Be Compliant.

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CISO Contributors: 

- Vijay Kumar Verma, Senior VP & Head Security Engineering - BCG
- Kabilan RK, Senior Manager - Tamilnad Marcantile Bank
- Sreenivas Vempati, Director IT Governance & Cybersecurity - RR Donnelley & Sons Co
- Manikant R Singh, VP & CISO - DMI Finance Private Limited
- Vidya Jayaraman, Executive Director Information Security & Compliance - AGS Health Private Limited
- Rajiv Bahl, Sr. VP & Field CTO - St. Fox Consulting Pvt. Ltd.