What this control covers
Execute DPDPA-compliant Data Processing Agreements with all data processors and sub-processors before any processing commences. DPAs must include: (i) DPDPA and Rules compliance obligation; (ii) erasure of data and cessation of processing upon consent withdrawal or termination; (iii) reasonable security safeguards; (iv) breach notification to Data Fiduciary within 24 hours of discovery; (v) restriction on sub-processor engagement without prior written approval; (vi) right of Data Fiduciary to audit processor compliance. Objective: Establish full contractual accountability of processors under DPDPA, minimising data fiduciary liability for processor-caused breaches or non-compliance.
Why it matters
Risk is the language an executive team understands; this control connects technical reality to board-level decisions and budget allocation.
How to implement
AWS
Codify the policy intent as SCPs, AWS Config conformance packs, and Security Hub standards so the cloud enforces what the document says.
Azure
Codify in Azure Policy initiatives (built-in regulatory compliance for CIS, ISO 27001, SOC 2, HIPAA) and assign at management-group level.
GCP
Use Cloud KMS with customer-managed encryption keys (CMEK) for BigQuery, GCS, and Compute. Sensitive Data Protection (DLP API) inspects/de-identifies PII at scale.
Google Workspace
Enable client-side encryption for Drive/Docs and turn on Drive Labels + DLP rules to prevent external sharing of regulated data classes.
On-premises
Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.
Evidence to collect
policy_document— A signed, version-controlled policy stating leadership intent and the named owner.vendor_risk_management— See the iCompaas Evidence library for the canonical source for this evidence type.
Signed policies, procedures, and registers document the safeguard. Processor due diligence, DPAs, and transfer registers evidence third-party controls. Focus: Data Processing Agreements (DPA) - Full Compliance.
Quick checklist
- Restrict — Data Processing Agreements (Dpa) / Full Compliance
- Execute — Data Processing Agreements (Dpa) / Full Compliance
Related articles on this site
- GDPR Article 19: Notification Obligation Regarding Rectification or Erasure of Personal Data or Restriction of Processing
- Data Privacy Regulations
- NIST 800-171 3.1.9 Provide privacy and security notices consistent with applicable CUI rules.
- CMMC 2.0 AC.2.005 Provide privacy and security notices consistent with applicable CUI rules.