India DPDP Act 2023·Control IR-002·critical·Component: Incident Response

What this control requires

Implement a data subject breach notification procedure including: (i) pre-approved communication template compliant with Rule 7 (nature of breach, potential impact, mitigation steps, contact for queries); (ii) automated notification trigger linked to breach detection systems; (iii) notification mechanism documentation (email, SMS, in-app); (iv) timeline tracking from breach detection to data subject notification; (v) delivery confirmation logs. Objective: Ensure affected data principals are notified promptly and comprehensively upon a personal data breach, enabling them to take protective action.
— India DPDP Act 2023, Control IR-002

In plain English

Implement a data subject breach notification procedure including: (i) pre-approved communication template compliant with Rule 7 (nature of breach, potential impact, mitigation steps, contact for queries); (ii) automated notification trigger linked to breach detection systems; (iii) notification mechanism documentation (email, SMS, in-app); (iv) timeline tracking from breach detection to data subject notification; (v) delivery confirmation logs. 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-002) 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.
  • Document. Document the trigger, the owner and the cadence.
  • Ensure. Document the trigger, the owner and the cadence.
  • Scope: personal data breach, data subject 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 - Data Subject 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