India DPDP Act 2023·Control SE-004·high·Component: Security

What this control requires

Maintain regular backups of all personal data systems. Test backup restoration quarterly. Ensure backup storage is encrypted and access-controlled. Document RTO and RPO for all personal data systems. Objective: Ensure availability and recovery of personal data following a security incident, breach, or system failure.
— India DPDP Act 2023, Control SE-004

In plain English

Maintain regular backups of all personal data systems. In practice, this means you can prove you maintain personal data backup-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-004) and look for objective evidence on the latest two assessment cycles.

How to implement

Business Continuity

BC/DR. Define RTO/RPO per service, test backup restoration quarterly, and run a tabletop of full-region failover annually.

Backups. Immutable backups (S3 Object Lock / Azure immutable storage / GCS bucket lock) plus an air-gapped copy for ransomware resilience.

Operational checklist

  • Maintain. Document the trigger, the owner and the cadence.
  • Document. Document the trigger, the owner and the cadence.
  • Ensure. Document the trigger, the owner and the cadence.
  • Scope: personal data backup, recovery.

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 Backup & Recovery.

Common pitfalls

  • DR plans that have never been tested in earnest, or that depend on an MFA token only one person can produce.

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: business continuitydata protectionbackup recovery