India DPDP Act 2023·Control DS-001·high·Component: Data Subject Rights

What this control requires

Implement a documented DSAR procedure covering the Right to Be Informed (Sec 11). The procedure must enable the organisation to provide data principals with: (i) summary of personal data being processed; (ii) description of processing activities; (iii) identities of all data fiduciaries with whom data has been shared and description of shared data; and (iv) any other information prescribed by Rules. Maintain a data sharing register to enable accurate fulfilment of (iii). Objective: Ensure data principals can exercise their information rights efficiently and within prescribed timelines, with accurate and complete responses.
— India DPDP Act 2023, Control DS-001

In plain English

Implement a documented DSAR procedure covering the Right to Be Informed (Sec 11). In practice, this means you can prove you maintain data subject access request (dsar)-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 Subject Rights, the assessor will trace your implementation back to the catalogue reference (Control DS-001) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

  • Maintain. Document the trigger, the owner and the cadence.
  • Implement. Document the trigger, the owner and the cadence.
  • Document. Document the trigger, the owner and the cadence.
  • Scope: data subject access request (dsar), information rights.

Evidence to collect

  • Ticketing Workflow. ticketing_workflow evidence
  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. Service management or grievance ticketing records prove timely handling. Focus: Data Subject Access Request (DSAR) - Information Rights.

Common pitfalls

  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

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.

Related controls in India DPDP Act 2023

References

Topics: data protectiongovernance riskprivacy managementpolicy management