India DPDP Act 2023 DP-001 — Data Processing Agreements (DPA) - Full Compliance

What this control requires

Execute DPDPA-compliant Data Processing Agreements with all data processors and sub-processors before any processing commences. DPAs must include: (i) DPDPA and Rules compliance obligation; (ii) erasure of data and cessation of processing upon consent withdrawal or termination; (iii) reasonable security safeguards; (iv) breach notification to Data Fiduciary within 24 hours of discovery; (v) restriction on sub-processor engagement without prior written approval; (vi) right of Data Fiduciary to audit processor compliance. Objective: Establish full contractual accountability of processors under DPDPA, minimising data fiduciary liability for processor-caused breaches or non-compliance.

In plain English

Execute DPDPA-compliant Data Processing Agreements with all data processors and sub-processors before any processing commences. In practice, this means you can prove you restrict data processing agreements (dpa)-level controls on a defined cadence.

Why it matters

Penalties under the DPDP Act reach ₹250 crore per instance of significant non-compliance, and the Act applies extra-territorially to any entity processing personal data of individuals in India in connection with offering goods or services.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

Indian DPAs and statutory auditors will look for: documented consent capture and revocation flows, a designated Data Protection Officer (for Significant Data Fiduciaries), breach-notification workflows tied to Data Protection Board notification timelines, and Records of Processing that match the consent notice the user saw.

Within Data Processing, the assessor will trace your implementation back to the catalogue reference (Control DP-001) and look for objective evidence on the latest two assessment cycles.

How to implement

1. Write a short policy stating intent, scope and named owner.
2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

• Restrict. Document the trigger, the owner and the cadence.
• Execute. Document the trigger, the owner and the cadence.
• Scope: data processing agreements (dpa), full compliance.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.
• Vendor Risk Management. vendor_risk_management evidence

Signed policies, procedures, and registers document the safeguard. Processor due diligence, DPAs, and transfer registers evidence third-party controls. Focus: Data Processing Agreements (DPA) - Full Compliance.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• ISO/IEC 27701:2025 A.2.2.7 — Records related to processing PII

Related controls in India DPDP Act 2023

• Control IT-001 — International Data Transfer Register & Restriction Screening
• Control IT-002 — Cross-Border Data Transfer Policy & Overseas Processor Contracts
• Control SC-008 — Children's Data Processing Controls
• Control SC-005 — Data Processor Register & DPA Management

References

• Ministry of Electronics and Information Technology (India) — India DPDP Act 2023
• Catalogue identifier: Control DP-001

Topics: governance riskvendor riskdata protectionprivacy managementvendor management