India DPDP Act 2023·Control IR-001·critical·Component: Incident Response

What this control requires

Implement a Personal Data Breach Response procedure including: (i) breach detection and classification (personal data breach vs. non-personal breach); (ii) DPB notification in prescribed form under Rule 7 (immediately upon discovery); (iii) 72-hour detailed breach report to DPB; (iv) breach register with detection timestamp, notification timestamp, and root cause; (v) annual breach response simulation. Objective: Ensure timely and compliant notification to the Data Protection Board upon any personal data breach, minimising penalty exposure and demonstrating proactive compliance.
— India DPDP Act 2023, Control IR-001

In plain English

Implement a Personal Data Breach Response procedure including: (i) breach detection and classification (personal data breach vs. In practice, this means you can prove you implement personal data breach-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 critical in the source catalogue. Treat gaps here as production incidents in the risk register, not housekeeping.

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 Incident Response, the assessor will trace your implementation back to the catalogue reference (Control IR-001) and look for objective evidence on the latest two assessment cycles.

How to implement

Incident Response

Runbook. Maintain a runbook keyed by incident type with named roles (IC, comms, scribe), an out-of-band comms channel, and a 72-hour timeline for external notification.

Tabletop. Run a quarterly tabletop exercise (ransomware, insider, supply-chain) and feed gaps back into the runbook.

Operational checklist

  • Implement. Document the trigger, the owner and the cadence.
  • Ensure. Document the trigger, the owner and the cadence.
  • Scope: personal data breach, dpb notification.

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: Personal Data Breach - DPB Notification.

Common pitfalls

  • Runbooks that name a role but no person, or list a paging channel that no longer exists.

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: incident responsedata protectionevent alert