India DPDP Act 2023·Control SE-005·high·Component: Security

What this control requires

Implement organisational security governance including: (i) approved Information Security Policy covering personal data; (ii) annual employee security awareness training (including DPDPA obligations); (iii) annual internal DPDPA compliance audit; (iv) management review of security posture. For SDFs: engage independent data auditor under Rule 12. Objective: Embed data protection governance across the organisation through policy, training, and regular audit, demonstrating systemic compliance.
— India DPDP Act 2023, Control SE-005

In plain English

Implement organisational security governance including: (i) approved Information Security Policy covering personal data; (ii) annual employee security awareness training (including DPDPA obligations); (iii) annual internal DPDPA compliance audit; (iv) management review of security posture. In practice, this means you can prove you implement information security governance-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-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.

Operational checklist

  • Implement. Document the trigger, the owner and the cadence.
  • Review. Document the trigger, the owner and the cadence.
  • Scope: information security governance, training, audit.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. Focus: Information Security Governance, Training & Audit.

Common pitfalls

  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

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: governance riskawareness trainingpolicy managementsecurity training