Automating DPDP Compliance: A Practical Primer on the Rules for Indian Businesses

Dec 4, 2025

Article by

GoTrust

Introduction 
In the past few years, Indian businesses in areas like e-commerce, SaaS, fintech, HR platforms, and more have increasingly adopted data-centric approaches. Things like Customer sign-ups, digital onboarding, usage tracking, analytics, personalisation, and cloud-based storage have all become standard practice. Consequently, gathering, handling, and profiting from people's personal information is now a common occurrence. But, as the saying goes, with great power comes great responsibility. Recognising this, lawmakers have now put in place a thorough legal structure. The Digital Personal Data Protection Act of 2023 (DPDP Act), along with the recently notified Digital Personal Data Protection Rules of 2025 (DPDP Rules 2025), means that adhering to these regulations is now absolutely essential.  

This blog offers a hands-on guide. It will outline what businesses actually need to do and provide a plan for automating compliance. We'll explain why "automation" is so important. Given the vast number of digital users in India, only automated systems can guarantee the level of consistency, readiness for audits, and reduction in mistakes that are needed to genuinely prove compliance. 

DPDP's Statutory Foundation and the Operational Mandate of the Rules 

With the Digital Personal Data Protection Act, 2023, and the DPDP Rules, 2025 that followed, India has entered a phase of data governance that focuses on accountability. The Act and the Rules cover the processing of digital personal data within the country, whether it is collected online or gathered offline and then converted into digital form. The law also applies to the handling of personal data outside India if it is related to providing goods or services to individuals in India.  

The Act sets up the main legal framework for this purpose: 

  • Section 5 (Notice): Mandates that a Data Fiduciary provide notice to the Data Principal detailing the data collected, its purpose, and the rights of the individual, prior to obtaining consent. 

  • Section 6 (Consent): Requires consent to be free, specific, informed, unambiguous, and unconditional, with a clear affirmative action, and critically, gives the Data Principal the right to withdraw it anytime. 

  • Section 8 (General Obligations): Imposes general duties on Data Fiduciaries, including ensuring the accuracy and security of data, and deleting it when the purpose is met, or consent is withdrawn. 

  • Section 10 (Significant Data Fiduciaries): Imposes enhanced obligations, such as conducting a Data Protection Impact Assessment (DPIA) and appointing a Data Protection Officer (DPO) on entities that process data at a large scale, due to the high risk they pose. 

The Rules, notified on November 14, 2025, provide the operational layer that highlights the need for immediate system changes. 

Major Compliance Requirements Under the Rules 

  • Data Retention and Storage Limitation: Rule 8 provides detailed guidelines on duration, including a mandatory minimum retention of logs for at least one year for audit purposes. It also outlines secure disposal procedures and a 48-hour advance notice requirement to the Data Principal before certain categories of data erasure. 

  • Security Safeguards: Rule 6 makes technical and organisational measures explicit. This includes, at a minimum, encryption, obfuscation, or tokenisation of data, strict access control, and continuous logging and monitoring of data access, with logs retained for one year. 

  • Additional obligations of Significant Data Fiduciary: Rule 13 provides that a Significant Data Fiduciary shall, once in every period of twelve months from the date on which it is notified as undertake a Data Protection Impact Assessment and an audit to ensure effective observance of the provisions of this Act and the rules made thereunder. 

  • Consent Management & Grievance Mechanisms: The Rules mandate transparent and time-bound facilitation of Data Principals’ rights. This is especially relevant for handling the requests for access, correction, or withdrawal of consent, where Rule 14(3) stipulates a maximum response period of 90 days from the Data Fiduciary. 

  • Phased Compliance Timelines: The Rules envisage a structured implementation, granting an 18-month window (until May 2027) for full compliance with core operational requirements (like data lifecycle management and security safeguards). This allows businesses time to redesign systems, but also demands immediate strategic planning. 

What It Means for Businesses 

• Broad Coverage 
The Act applies to all digital personal data processing by companies that offer goods or services in India. This means almost every business, whether it's a big corporation or a small startup that collects things like names, email addresses, or cookies, now has to follow the rules. 

• Need to Reassess Data-Processing Lifecycle 
Companies must carefully track how data moves through their systems. This includes how data is collected, stored, processed, shared, kept, and deleted. Old systems like legacy databases, customer relationship management tools, and HR systems need a close look. The concept of purpose-limitation and data-minimisation will push businesses to change how they collect data, get consent, and manage how long they keep it. 

• Operational Overhead 
Following the Act comes with extra costs. Companies may need to update their infrastructure, like improving security, using encryption, and setting up access controls. There might also be delays in new features that involve data. For small and medium-sized businesses and startups, hiring experienced privacy experts and implementing strong technical protections can be expensive. 

• Potential Benefits: Trust, Competitiveness, and Risk Mitigation 
Businesses that follow the rules can gain an edge in the market. By showing they protect customer data well, they build trust with consumers, lower the risk of facing penalties, and prepare for possible data breaches. This also helps Indian companies work better with international privacy standards, like the European Union’s GDPR. 

Roadmap for Businesses: Automating Compliance: A Step-by-Step Guide 

Step 1: Data Mapping & Audit  

The critical first step. You cannot protect what you do not know you have. Perform a comprehensive audit: 

  • Identify all personal data collected (e.g., identity, financial, biometric, location). 

  • Document the purpose for collection, where it is stored, who accesses it (internal/third-party), and the retention period. 

  • Classify data according to sensitivity (e.g., children’s data) and flag high-risk processing activities for a DPIA. 

Step 2: Update Privacy Notices & Consent Flows  

Draft or update your privacy notice to be clear, transparent, and in accessible language, detailing the specific purpose of processing as mandated by the Act. Implement a Consent Management Platform (CMP) to ensure the consent mechanism is robust: 

  • Consent must be granular (specific to each purpose) and verifiable. 

  • The system must provide an easy, one-click mechanism to withdraw consent. 

Step 3: Governance & Accountability Structure  

  • Designate a point of contact for Data Principal requests and regulatory communication, even if not formally a Significant Data Fiduciary (SDF). SDFs must appoint a DPO based in India. 

  • Formalise data-protection policy, a mandatory breach-response policy, and detailed data retention & deletion policies. 

  • For SDFs, put in place annual DPIAs and independent data audits. 

Step 4: Implement Technical & Organisational Safeguards (Automation Tools)  

This is where automation becomes indispensable for meeting the demands of Rule 6 and Rule 8. 

  • Use encryption (at rest and in transit) and secure authentication (MFA) across all systems handling personal data. 

  • Use Role-Based Access Control (RBAC) to enforce data minimisation and purpose limitation by ensuring employees only access data necessary for their role. 

Build workflows to automatically flag and securely delete or archive personal data once the retention period expires or consent is withdrawn. 

  • Implement modular consent systems that manage user preferences centrally and automatically enforce them across all relevant processing systems (e.g., automatically excluding a user from a marketing list upon consent withdrawal). 

Step 5: Rights Management & Grievance Redressal Mechanism  

Implement a Data Subject Rights (DSR) automation tool. This system should: 

  • Automatically receive, log, and track Data Principal requests (access, correction, erasure, withdrawal). 

  • Coordinate data retrieval/deletion across multiple internal systems (CRM, databases, backups). 

  • Ensure that the mandatory 90-day response timeline is met, logging all actions and replies for audit. 

Step 6: Periodic Review, Audit, and Training  

Compliance is a continuous process. Conduct periodic internal compliance audits, train all employees on data-privacy obligations and breach-response protocols, and stay updated with the evolving guidelines from the DPBI. 

Challenges & How to Overcome Them with Gotrust. 

There are various specific challenges for different business scales. 

For SMEs  

  • The Problem: The costs of technical safeguards, audit, DPO/Grievance Officer, and compliance are often burdensome. It requires a budget and skilled personnel that small entities may lack. 

  • The Mitigation:  Adopt scalable automation solutions. Leveraging policy-kits and external DPO services can provide regulatory expertise without the full-time cost. Gotrust can provide template-driven, low-code policy deployment and integrated DPO-as-a-Service capabilities, making enterprise-grade compliance accessible. 

Legacy Systems & Data Backlog 

  • The Problem: Many organisations have legacy data collected over years without granular consent. Mapping and cleaning this data can be an enormous task, creating a high-risk backlog. 

  • The Mitigation: Prioritise high-risk and sensitive data first. Employ automated data discovery and classification tools to locate personal data across legacy systems. Implement a strict, automated data-minimisation and archival strategy for non-essential legacy data. Gotrust’s data mapping engine can rapidly crawl and classify data across heterogeneous legacy systems, identifying data that needs immediate cleansing or deletion according to Rule 8 retention periods. 

Maintaining Balance Between Compliance and Business Needs 

  • The Problem: Strict purpose limitation and consent requirements can seem to hamper certain data-driven features, such as advanced analytics, behavioural marketing, or profiling. 

  • The Mitigation: Re-evaluate business processes to avoid over-collection. Use anonymisation or pseudonymisation techniques where possible to allow for analytics without processing identifiable personal data. Implement explicit, informed consent for profiling or analytics purposes. Gotrust’s Consent Management Platform (CMP) is designed to capture granular, auditable consent that allows businesses to use data for permitted purposes while honouring the Data Principal's right to opt out of secondary uses.  

Continuous Compliance  

  • The Problem: As a new law, the DPDP framework will see evolving guidelines and clarifications from the DPBI, requiring continuous system and policy updates. 

  • The Mitigation: Build a flexible, agile policy framework. Consult legal experts periodically. Gotrust provides continuous compliance monitoring, automatically updating policy templates and internal controls in response to new DPBI guidelines or amendments, ensuring the compliance posture remains current without manual intervention. 

Conclusion 

The days of simply following privacy rules by reading long, ignored policies are over. Now, there's a new standard that requires businesses to take full responsibility, get clear permission from users, and implement strong data protection measures. These demands are hard to meet with outdated, manual methods. The 18-month compliance period is a chance to make major improvements. Organisations need to move beyond just updating policies and start investing in automating the entire privacy process. This change is not just about avoiding heavy fines, but also about turning regulation into a competitive edge. 

Gotrust understands both the challenges and the opportunities this shift brings. Our platform is specifically designed for DPDP rules and includes tools that automate key tasks. From data mapping and detailed consent management to handling data subject requests automatically (ensuring responses within 90 days) and maintaining continuous audit logs. 

Connect with Gotrust today to start mapping your data flow and ensure your compliance is ready for May 2027 and beyond.