India DPDP Act 2023 TR-001 — Standalone Privacy Notice

What this control requires

Provide a standalone privacy notice to data principals at or before seeking consent. The notice must be: (i) clear, plain, and not embedded in Terms & Conditions; (ii) specify all personal data collected and purposes; (iii) explain how rights under DPDPA may be exercised; (iv) provide details of how to complain to the Data Protection Board; and (v) provide DPO contact details. Objective: Ensure data principals are fully informed before giving consent, making all consent legally valid under the DPDPA.

In plain English

Provide a standalone privacy notice to data principals at or before seeking consent. In practice, this means you can prove you ensure standalone privacy notice-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 Transparency, the assessor will trace your implementation back to the catalogue reference (Control TR-001) 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

• Ensure. Document the trigger, the owner and the cadence.
• Provide. Document the trigger, the owner and the cadence.
• Scope: standalone privacy notice.

Evidence to collect

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

Signed policies, procedures, and registers document the safeguard. Focus: Standalone Privacy Notice.

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.

• ISO/IEC 27701:2025 A.1.2.6 — Privacy impact assessment
• NIST SP 800-53 Rev. 5 PT-5(1) — Just-In-Time Notice
• SOC 2 (2017 TSC) P3.2 — Consent Management for Personal Information Collection
• GDPR Article 2 — Material Scope

Related controls in India DPDP Act 2023

• Control LB-005 — Employee Privacy Notice & HR Data Governance
• Control TR-002 — Multi-Language Consent Interface
• Control LB-004 — Voluntary Disclosure Processing Notice & Opt-Out
• Control DS-005 — Consent Withdrawal Mechanism
• Control DS-007 — Grievance Redressal Mechanism
• Control GV-002 — Designated Representative Appointment

References

• Ministry of Electronics and Information Technology (India) — India DPDP Act 2023
• Catalogue identifier: Control TR-001

Topics: governance riskdata protectionprivacy managementpolicy management