SC-005·high·Component: Scope & ClassificationWhat this control requires
Maintain a complete register of all data processors and sub-processors. Execute DPDPA-compliant Data Processing Agreements (DPAs) with all processors before processing commences. DPAs must include: DPDPA compliance obligation, erasure/cessation upon consent withdrawal, security safeguards, breach notification obligation (24-hour notice to fiduciary), sub-processor approval requirement, and right to audit. Objective: Ensure all processors are contractually bound to DPDPA obligations, minimising fiduciary liability for processor-caused breaches or non-compliance.
In plain English
Maintain a complete register of all data processors and sub-processors. In practice, this means you can prove you maintain data processor register-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 Scope & Classification, the assessor will trace your implementation back to the catalogue reference (Control SC-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.
Asset Inventory
AWS. AWS Config Aggregator across every account + region gives a real-time inventory; ship the daily snapshot to S3 and surface drift in Security Hub.
Azure. Azure Resource Graph plus Defender for Cloud's inventory blade enumerates every subscription; export to Log Analytics for retention and Workbooks for reporting.
GCP. Cloud Asset Inventory exports a daily feed of every resource and IAM binding; query via BigQuery and alert on appearance/disappearance.
Endpoints. Pipe MDM telemetry (Intune / Jamf / Workspace ONE) into your CMDB so laptops and phones are inventoried with the same rigour as cloud resources.
Operational checklist
- Maintain. Document the trigger, the owner and the cadence.
- Ensure. Document the trigger, the owner and the cadence.
- Execute. Document the trigger, the owner and the cadence.
- Scope: data processor register, dpa management.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policies, procedures, and registers document the safeguard. Focus: Data Processor Register & DPA Management.
Common pitfalls
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
- Inventories that exclude SaaS, shadow IT and ephemeral cloud resources (Lambda, Cloud Run, K8s pods) miss the assets where most modern incidents start.
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.
- SOC 2 (2017 TSC) P3.2 — Consent Management for Personal Information Collection
- GDPR Article 14 — Information to be provided where personal data have not been obtained from the data subject
- CIS Controls v8 3.2 — Establish and Maintain a Data Inventory
- BSI C5:2020 AM-01 — Asset Inventory
- ISO/IEC 27701:2025 A.1.3.2 — Comply with obligations
Related controls in India DPDP Act 2023
- Control SC-002 — Data Principal Identification & Guardian Consent Management
- Control SC-001 — Digital Personal Data Inventory
- Control SC-008 — Children's Data Processing Controls
- Control SC-003 — Data Fiduciary Role Assignment & ROPA
- Control SC-004 — Significant Data Fiduciary (SDF) Self-Assessment
- Control SC-007 — Lawful Processing Matrix
References
- Ministry of Electronics and Information Technology (India) — India DPDP Act 2023
- Catalogue identifier:
Control SC-005
Topics: governance riskdata protectionprivacy managementpolicy managementasset inventory