Become DPDP Compliant by Protecting Personal Data with a Privacy Vault

With over 800 million internet users, India generates vast amounts of personal data daily through social media, e-commerce, fintech, and government platforms. Over the last few years, India has witnessed a dramatic increase in data breaches, exposing sensitive information from banking, healthcare, and telecom sectors – and has now enacted a comprehensive governmental law to enforce data privacy protections.

The DPDP Act, introduced in 2022 and now with the draft rules released in January 2025, enforces strict penalties to ensure companies prioritize personal data security. It is a critical step toward safeguarding individual privacy, strengthening cybersecurity around personal data, and fostering responsible data governance in India’s rapidly growing digital economy.

But complying with such a comprehensive regulation will not be easy.

Key Requirements: DPDP Rules

The DPDP Rules introduce strict obligations on businesses to ensure personal data privacy and security.

Critical highlights include:

• Security-first approach: Rule 6 details that strong data security measures like encryption, obfuscation, masking, tokenization, and access control must be applied to protect personal data.
• Data breach accountability: According to Rule 7, in the event of a breach, notifying affected individuals immediately and a detailed report to the Data Protection Board within 72 hours of a breach is mandatory.
• User-centric rights: In Rule 13, all persons, called “Data Principals” in the DPDP, have the right to access, correct, and erase their personal data.
• Data residency requirements: In Rule 14, data residency requirements are outlined, with the transfer of data outside of India subject to restrictions.
• Consent collection, enforcement, and revocation: Rules 3 and 4 require informed and verifiable user consent, as well as enforcement of consent collection.
• Additional restrictions regarding personal data of children: Most notably, Rules 10 and 11 mandate verifiable consent from a parent or legal guardian before processing data of children (ages 0-18).

Personal Data Sprawl Creates Massive Challenges for DPDP Compliance

In most systems, personal data, like a phone number, gets copied multiple times with replicas distributed throughout the system. This makes complying with requirements like:

• Right to erasure nearly impossible to execute
• Managing itemized consent extremely challenging
• Data breach notification and response cumbersome and inefficient

Historically, companies have tried to apply different point solutions to address this problem, like:

• Adding encryption to certain records
• Implementing governance layers
• Hardening server security
• Maintaining security patches and restricting access

However, these approaches add complexity and still do not satisfy all DPDP requirements. A new approach to data privacy and protection is required.

The Case for Personal Data Protection With a Data Privacy Vault

1. Isolated and Protected Personal Data Reduces Risk

A data vault for PII discovers and transforms all sensitive personal data records, reducing:

• Risk of accidental exposure
• Data breaches
• Unauthorized access

By isolating PII and treating it as a separate, highly protected class of data, organizations can apply stringent access controls, encryption, tokenization, and monitoring mechanisms, ensuring compliance with DPDP requirements.

2. Simplifies Data Subject Rights Management

The DPDP mandates enabling individuals to exercise rights such as access, rectification, erasure (the “right to be forgotten”), and data portability. When PII is protected with a data vault:

• Relevant data can be identified and retrieved quickly.
• Modifications, deletions, and exports can be executed with minimal operational overhead.
• Compliance is ensured without significant disruptions to other business processes.

3. Enforces Consent and Purpose Limitation

Identifying and transforming PII with a data vault enables dynamic consent enforcement, a critical requirement under the DPDP.

• Granular Consent Management: Data vaults can store consent metadata alongside PII, including the scope of consent, purpose, and validity period.
• Real-Time Consent Validation: Before accessing or processing PII, systems can reference the data vault to ensure consent is valid and aligns with the original purpose.
• Consent Revocation: When individuals withdraw consent, the vault can immediately flag the relevant PII as restricted, halting further processing and ensuring compliance with data minimization and usage principles.
• Retroactive Consent: Ensuring compliance for data collected before DPDP was enacted.

4. Facilitates Auditability and Regulatory Reporting

A data vault provides a clear, auditable trail for data access, usage, and consent enforcement, which is essential for demonstrating compliance during audits.

• Consent and Governance Audits: Organizations can demonstrate that every use of PII aligns with valid consent.
• Access Logs: The vault captures a detailed record of who accessed the data, when, and for what purpose, ensuring transparency and accountability.

Data Privacy Vault: The Strategic Approach to DPDP Compliance

Protecting PII with a data privacy vault is a strategic approach to effortlessly meet DPDP requirements. By incorporating robust consent enforcement mechanisms, organizations can:

• Demonstrate compliance with purpose limitation, transparency, and user rights
• Reduce operational complexity and enhance data security
• Foster trust with customers and strengthen organizational resilience in a rapidly evolving privacy landscape