India DPDP Act 2023·Control SE-003·high·Component: Security

What this control requires

Log all access to personal data systems, including: user ID, timestamp, data accessed, action performed. Integrate logs into a SIEM for real-time monitoring and alerting. Set alerts for unauthorised access, unusual access patterns, and policy violations. Retain logs for minimum 1 year (Rule 6(1)(e)). Objective: Enable detection, investigation, and audit of all access to personal data, supporting breach detection and forensic investigation.
— India DPDP Act 2023, Control SE-003

In plain English

Log all access to personal data systems, including: user ID, timestamp, data accessed, action performed. In practice, this means you can prove you log personal data access logging-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-003) 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

  • Log. Document the trigger, the owner and the cadence.
  • Monitor. Document the trigger, the owner and the cadence.
  • Scope: personal data access logging, siem monitoring.

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: Personal Data Access Logging & SIEM Monitoring.

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: logging monitoringdata protectionsiemlogging retentioncontinuous monitoring