India DPDP Act 2023 GV-001 — Data Protection Officer (DPO) Appointment & Publication

What this control requires

Formally appoint a Data Protection Officer (or designated contact person) through a board/management-level decision. Define the DPO's role, responsibilities, and reporting line. For SDFs, ensure the DPO is India-based and directly accountable to the board. Publish DPO contact details prominently on the website and application. Include DPO details in all DSAR responses. Objective: Establish an accountable, named contact for data principal queries, regulatory communications, and grievance redressal.

In plain English

Formally appoint a Data Protection Officer (or designated contact person) through a board/management-level decision. In practice, this means you can prove you define data protection officer (dpo) appointment-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 Governance, the assessor will trace your implementation back to the catalogue reference (Control GV-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

• Define. Document the trigger, the owner and the cadence.
• Ensure. Document the trigger, the owner and the cadence.
• Designate. Document the trigger, the owner and the cadence.
• Scope: data protection officer (dpo) appointment, publication.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. Focus: Data Protection Officer (DPO) Appointment & Publication.

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.

• GDPR Article 38 — Position of the data protection officer
• SOC 2 (2017 TSC) P2.1 — Communication of Data Subject Choices and Consequences
• ISO/IEC 27701:2025 A.1.3.2 — Comply with obligations
• BSI C5:2020 CRY-01 — Policy for the use of encryption procedures and key management
• NIST SP 800-53 Rev. 5 SI-19(1) — Collection

Related controls in India DPDP Act 2023

• Control GV-002 — Designated Representative Appointment
• Control PD-001 — Data Protection Impact Assessment Programme
• Control DS-008 — Data Principal Nomination Mechanism
• Control DS-002 — Right of Access - Data Copy Provision
• Control LB-005 — Employee Privacy Notice & HR Data Governance
• Control SC-001 — Digital Personal Data Inventory

References

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

Topics: governance riskdata protectionpolicy managementprivacy management