India DPDP Act 2023·Control SE-002·high·Component: Security

What this control requires

Implement role-based access control (RBAC) for all systems containing personal data, enforcing least-privilege access. Conduct quarterly access reviews. Disable credentials unused for 90 days. Enforce MFA for all users with access to personal data systems. Objective: Prevent unauthorised access to personal data by limiting access to only those with a legitimate business need, in accordance with Rule 6(1).
— India DPDP Act 2023, Control SE-002

In plain English

Implement role-based access control (RBAC) for all systems containing personal data, enforcing least-privilege access. In practice, this means you can prove you implement role-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 Security, the assessor will trace your implementation back to the catalogue reference (Control SE-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.
  • Conduct. Document the trigger, the owner and the cadence.
  • Review. Document the trigger, the owner and the cadence.
  • Scope: role, based access control (rbac), least privilege.

Evidence to collect

  • Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.
  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. IAM analytics confirm RBAC, MFA, and access reviews. Focus: Role-Based Access Control (RBAC) & Least Privilege.

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: identity accessprivileged accessdata protectionidentity managementaccess reviewmulti factor auth