India DPDP Act 2023 LB-005 — Employee Privacy Notice & HR Data Governance

What this control requires

Issue a formal Employee Privacy Notice at onboarding, informing employees of all HR-related personal data processing activities, purposes, and rights. Implement an HR Data Processing Procedure governing collection, storage, access, and retention of employee personal data. Maintain an access control matrix for systems containing employee data. Objective: Ensure employee personal data processing is lawful, transparent, and governed, with employees informed of their data rights under the DPDPA.

In plain English

Issue a formal Employee Privacy Notice at onboarding, informing employees of all HR-related personal data processing activities, purposes, and rights. In practice, this means you can prove you maintain employee privacy notice-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 Lawful Basis, the assessor will trace your implementation back to the catalogue reference (Control LB-005) 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.
• Ensure. Document the trigger, the owner and the cadence.
• Scope: employee privacy notice, hr data governance.

Evidence to collect

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

Signed policies, procedures, and registers document the safeguard. Focus: Employee Privacy Notice & HR Data Governance.

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.

• ISO/IEC 27701:2025 A.1.2.6 — Privacy impact assessment
• GDPR Article 14 — Information to be provided where personal data have not been obtained from the data subject
• NIST SP 800-53 Rev. 5 PT-5(1) — Just-In-Time Notice
• SOC 2 (2017 TSC) P2.1 — Communication of Data Subject Choices and Consequences

Related controls in India DPDP Act 2023

• Control TR-001 — Standalone Privacy Notice
• Control LB-004 — Voluntary Disclosure Processing Notice & Opt-Out
• Control LB-001 — Consent Quality & Management
• Control DS-008 — Data Principal Nomination Mechanism
• Control LB-002 — Legal Obligation Processing Register
• Control DS-002 — Right of Access - Data Copy Provision

References

• Ministry of Electronics and Information Technology (India) — India DPDP Act 2023
• Catalogue identifier: Control LB-005

Topics: governance riskdata protectionprivacy managementpolicy management