India DPDP Act 2023·Control IT-002·high·Component: International Transfer

What this control requires

Implement a Cross-Border Data Transfer Policy governing: permissible transfer destinations, required contractual safeguards for overseas processors, transfer impact assessment procedure, and transfer register maintenance. Include DPDPA-specific data transfer clauses in all overseas processor contracts. Objective: Ensure all cross-border data transfers are governed by a documented policy and that overseas processors are contractually bound to DPDPA requirements.
— India DPDP Act 2023, Control IT-002

In plain English

Implement a Cross-Border Data Transfer Policy governing: permissible transfer destinations, required contractual safeguards for overseas processors, transfer impact assessment procedure, and transfer register maintenance. In practice, this means you can prove you implement cross-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 International Transfer, the assessor will trace your implementation back to the catalogue reference (Control IT-002) 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

  • 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: cross, border data transfer policy, overseas processor contracts.

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: Cross-Border Data Transfer Policy & Overseas Processor Contracts.

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 riskvendor riskprivacy managementvendor management