India DPDP Act 2023·Control SE-001·critical·Component: Security

What this control requires

Encrypt all personal data at rest and in transit using industry-standard algorithms (AES-256 for rest, TLS 1.2+ for transit). Apply data masking or tokenisation for personal data in non-production environments and display contexts. Objective: Prevent unauthorised access to personal data through encryption, reducing breach impact and demonstrating reasonable security safeguards under Rule 6(1).
— India DPDP Act 2023, Control SE-001

In plain English

Encrypt all personal data at rest and in transit using industry-standard algorithms (AES-256 for rest, TLS 1.2+ for transit). In practice, this means you can prove you encrypt encryption-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 Security, the assessor will trace your implementation back to the catalogue reference (Control SE-001) 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

  • Encrypt. Document the trigger, the owner and the cadence.
  • Scope: encryption, data masking.

Evidence to collect

  • Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.
  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. Infrastructure posture tooling (AWS/Azure/GCP configuration, encryption, backup, logging) verifies technical enforcement. Focus: Encryption & Data Masking.

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.

References

Topics: data protectionencryption at restencryption in transitkey management