DPDP Act Compliance: How ISO Consultants Help Organisations in India Get Ready

India’s Digital Personal Data Protection (DPDP) Act, 2023 establishes a legal framework for processing digital personal data and protecting the rights of individuals. The Act applies to organisations that process digital personal data within its scope and introduces responsibilities for Data Fiduciaries and rights for Data Principals.

For organisations preparing for DPDP compliance, the focus goes beyond privacy policies. Data protection can involve processes, technology, information security, employee awareness, documentation, risk management and ongoing monitoring.

The DPDP Act and the Digital Personal Data Protection Rules, 2025 are being brought into effect in phases. This makes it important for organisations to understand the applicable requirements and prepare their privacy and security practices in advance.

DPDP Act consultancy can provide structured support to help organisations assess their current practices, identify gaps and establish processes aligned with applicable data protection requirements.

What Is the DPDP Act?

The Digital Personal Data Protection Act, 2023 is India's legal framework for the processing of digital personal data.

The Act defines key roles including:

• Data Fiduciary: An organisation or person that determines the purpose and means of processing personal data.

• Data Principal: The individual to whom the personal data relates.

• Child: An individual who has not completed 18 years of age.

The Act provides individuals with rights relating to their personal data, while organisations processing personal data have defined responsibilities.

The Digital Personal Data Protection Rules, 2025 provide additional details and an implementation framework for the Act. The Rules have also been notified with a phased commencement schedule.

What Does the DPDP Act Require?

The specific obligations depend on the applicable provisions, the organisation's role and the type of processing involved.

Key areas include:

1. Consent and Lawful Processing

Where consent is the applicable basis for processing, organisations need to obtain consent that meets the requirements of the DPDP Act and provide individuals with a mechanism to withdraw consent.

The Act also recognises certain specified legitimate uses for processing personal data.

2. Children's Data

The DPDP Act defines a child as an individual who has not completed 18 years of age.

The Act contains specific requirements relating to verifiable parental consent and restrictions concerning tracking, behavioural monitoring and targeted advertising directed at children.

3. Data Security and Protection

Data Fiduciaries are required to take reasonable security safeguards to prevent personal data breaches and meet other applicable obligations under the Act and Rules.

This makes information security, access management, incident handling, employee awareness and appropriate technical and organisational measures important areas for organisations preparing for DPDP compliance.

4. Data Retention and Deletion

Organisations should understand what personal data they collect, why it is processed, how long it is retained and when it should be deleted or otherwise handled according to applicable requirements.

A documented data lifecycle can help organisations manage these activities more consistently.

DPDP Act and Cybersecurity: How Are They Connected?

Data privacy and cybersecurity are related, but they are not the same.

The DPDP framework focuses on the processing and protection of digital personal data and the rights and obligations established by the law. Cybersecurity focuses more broadly on protecting systems, networks, applications and information from security threats.

For example, an organisation preparing for DPDP compliance may need to consider:

• Access controls

• Data classification

• Security safeguards

• Incident management

• Employee awareness

• Vendor and third-party risks

• Data retention practices

• Business continuity

• Monitoring and review

This is where a structured information security management approach can support broader data protection readiness.

How ISO/IEC 27001 Can Support DPDP Readiness

ISO/IEC 27001:2022 specifies requirements for establishing, implementing, maintaining and continually improving an Information Security Management System (ISMS).

It provides a systematic, risk-based approach to information security, including areas such as:

• Information security risk assessment

• Asset and information management

• Access control

• Information security policies

• Incident management

• Supplier and third-party security

• Employee awareness and training

• Business continuity

• Internal audits

• Corrective actions

• Management review

• Continual improvement

ISO/IEC 27001 can therefore provide a structured foundation for managing information security risks that may also be relevant to personal data protection.

However, ISO/IEC 27001 certification does not automatically mean that an organisation is compliant with every requirement of the DPDP Act. Organisations should assess the legal and operational requirements that apply to their specific processing activities.

How ISO Consultants Help with DPDP Compliance

ISO consultants can support organisations in translating requirements into practical processes and controls.

Depending on the organisation's needs, consultancy support may include:

1. Gap Assessment

A consultant can review existing privacy, information security and operational practices against applicable requirements and identify areas that require attention.

2. Risk Assessment

Organisations can identify risks associated with personal data, information systems, employees, suppliers and business processes.

3. Policy and Documentation Support

Consultants can help organisations develop or improve relevant policies, procedures, registers, controls and supporting documentation.

4. Security and Process Controls

Where ISO/IEC 27001 is part of the organisation's approach, consultants can help establish an ISMS and implement appropriate information security controls based on identified risks.

5. Employee Training and Awareness

Employees play an important role in protecting personal and organisational information. Training can help employees understand applicable privacy, security and data-handling responsibilities.

6. Internal Audits and Readiness Reviews

Internal assessments can help organisations identify gaps before formal reviews, customer assessments or other compliance activities.

7. Continual Improvement

Privacy and information security practices should be reviewed periodically as business processes, technologies, risks and applicable requirements change.

For organisations considering ISO certification, an ISO readiness assessment can also help identify gaps before engaging with an independent certification body.

How MSCi Supports Data Protection Readiness

MSCi provides ISO consultancy services to help organisations understand applicable ISO requirements, identify implementation gaps, develop relevant documentation, implement processes and prepare for certification audits.

For organisations working towards stronger data protection and information security practices, MSCi can support areas such as:

• ISO/IEC 27001 readiness and implementation support

• Information security risk assessment

• Documentation and policy development

• Employee awareness and training

• Internal audit support

• Corrective action planning

• Management system improvement

Organisations should assess their DPDP obligations separately and determine which legal, privacy and security measures are applicable to their specific activities.

Frequently Asked Questions

1. What is the DPDP Act?

The Digital Personal Data Protection Act, 2023 is India's legal framework governing the processing of digital personal data. It establishes obligations for Data Fiduciaries and rights for Data Principals.

2. Is the DPDP Act applicable to all businesses?

Applicability depends on the scope and circumstances specified under the Act. Organisations should assess whether their processing activities fall within the Act and which provisions apply to them.

3. What are the DPDP Rules 2025?

The Digital Personal Data Protection Rules, 2025 provide additional details and implementation mechanisms for the DPDP Act. The Rules were notified with a phased commencement schedule.

4. Can ISO/IEC 27001 help with DPDP compliance?

ISO/IEC 27001 can support organisations by providing a structured approach to information security risk management, controls, documentation and continual improvement. However, ISO/IEC 27001 certification does not by itself establish compliance with every requirement of the DPDP Act.

5. Is ISO/IEC 27001 mandatory under the DPDP Act?

ISO/IEC 27001 is not generally stated as a mandatory certification requirement under the DPDP Act. Organisations should determine the specific security and privacy measures applicable to their activities.

6. What should an organisation do first for DPDP readiness?

An organisation can begin by understanding whether the DPDP Act applies to its activities, identifying the personal data it processes, reviewing how that data is collected and used, assessing relevant risks and identifying gaps in its existing privacy and security practices.

Conclusion

DPDP readiness involves more than creating a privacy policy. Organisations need to understand their data processing activities, applicable legal requirements, security risks, internal processes and responsibilities.

ISO/IEC 27001 can provide a structured information security management framework that supports risk assessment, security controls, documentation, employee awareness and continual improvement. ISO consultants can help organisations implement these management-system practices and prepare for certification where required.

For organisations in India, combining a clear understanding of DPDP requirements with appropriate privacy and information security practices can provide a structured approach to data protection readiness.

Sources

1. DPDP Act, 2023 Government of India, India Code: https://www.indiacode.nic.in/indiacode/handle/123456789/22037?view_type=browse 

2. Digital Personal Data Protection Rules, 2025 Ministry of Electronics and Information Technology (MeitY) https://xn--m1bdba5a7gresc7dsa.xn--11b7cb3a6a.xn--h2brj9c/documents/act-and-policies/digital-personal-data-protection-rules-2025-gDOxUjMtQWa?pageTitle=Digital-Personal-Data-Protection-Rules-2025 

3. Enforcement Timeline for the DPDP Act — Ministry of Electronics and Information Technology (MeitY) https://xn--m1bdba5a7gresc7dsa.xn--11b7cb3a6a.xn--h2brj9c/documents/act-and-policies?page=1 

4. ISO/IEC 27001:2022 ISMS International Organization for Standardization (ISO) https://www.iso.org/standard/88435.html? 

5. ISO/IEC 27000 Family Information Security Management : https://www.iso.org/standard/iso-iec-27000-family