DPDP Rules 2025: What Every CXO Must Know and How to Prepare

India’s digital footprint has grown fast over the last decade. With that growth comes a basic responsibility: handle people’s personal data with more care. The Digital Personal Data Protection (DPDP) Act, 2023, which came into force on 11 August 2023, and the DPDP Rules, 2025, effective 14 November 2025, now set the expectations clearly.

This update isn’t a light policy tweak. It affects how organisations collect data, store it, use it and retire it. It also shapes decisions in product, security, HR, marketing and vendor management. For CISOs, CIOs, CTOs, CDOs, CHROs, CFOs and General Counsels, the Act is both an operating constraint and a chance to build a stronger, more predictable data environment.

Key Takeaways

• India now runs on a complete, enforceable personal data protection law
• The Act protects individual rights while still allowing legitimate business use.
• The Rules give operational clarity on consent, security, breach reporting and grievance handling.
• Organisations carry full responsibility for how personal data moves and is protected.
• CXOs need to drive alignment across teams and systems; this won’t fix itself

What is the DPDP Act?

The Act governs the processing of digital personal data, whether collected online or digitised later. It applies to:

• Indian companies,
• Foreign companies offering goods or services in India, and
• Any entity that processes personal data digitally.

It sets out rights for individuals (Data Principals) and obligations for organisations (Data Fiduciaries). The intention is to create clarity, consistency and accountability.

Key Objectives of the DPDP Act

• Give individuals meaningful control over their data.
• Allow businesses to innovate without over-collecting or misusing data.
• Reduce misuse through purpose limitation and data minimisation.
• Raise the baseline for security practices.
• Introduce penalties and oversight to keep everyone honest.

DPDP Rules, 2025: What’s new

1. Consent & notices

Notices must be precise and easy to read. Consent must be specific and simple to withdraw.

2. Security safeguards

Organisations must maintain:

• Encryption
• Access control
• Monitoring and logs
• Backup and disaster recovery
• Incident detection and response processes

These are table stakes, not “good to have”.

3. Breach reporting

Breaches must be reported quickly to the Data Protection Board and to affected users. Long delays and vague updates will attract penalties.

4. Grievance redressal

Every organisation must publish a grievance route and meet the timelines they commit to.

5. Significant Data Fiduciaries (SDFs)

If classified as an SDF, the organisation must appoint an India-based DPO, undergo independent audits and run periodic impact assessments.

Rights of Data Principals (Individuals)

People can request:

• Access to their data
• Corrections
• Deletion
• Consent withdrawal
• Grievance escalation
• Nomination of someone to act on their behalf

Systems must be able to respond, not just acknowledge.

Obligations of Data Fiduciaries (Businesses & Entities)

Organisations must:

• Collect only necessary data
• Use it only for the purposes declared
• Keep it accurate and secure
• Delete it when no longer needed
• Ensure vendors follow similar standards
• Report breaches responsibly

What CXOs Must Do Now – A Practical, Actionable Playbook

DPDP (Digital Personal Data Protection) forces organisations to treat personal data with the same discipline they apply to financials or compliance records. Most companies don’t operate that way today, which is why this requires active CXO involvement.

1. Set up a unified data governance structure

Bring Security, IT, Legal, HR, Marketing, Product and Operations into one working group.
Align on:

• What data you collect
• Why you collect it
• Ownership
• Retention timelines
• Deletion rules

This prevents each function from running its own version of “privacy”.

2. Map how data moves in your organisation

List out:

• All systems storing personal data
• Where it travels internally
• Which vendors access it
• How long it stays in each place

Once mapped, the gaps and redundancies become obvious. It’s the starting point for any serious remediation.

3. Strengthen security with DPDP expectations in mind

Most organisations have partial controls, but not a unified posture.
Review and upgrade:

• Access control
• Encryption
• Logging and monitoring
• Backup and recovery
• Incident workflows

DPDP expects the basics to be consistently applied.

4. Update consent and notice experiences

Revisit:

• Website and app onboarding
• Lead forms
• Employee data collection flows
• Marketing journeys

The aim is clarity and purpose specificity. Some tracking and analytics flows may need to be reworked.

5. Reinforce vendor and SaaS governance

Vendors are often where the real risk sits.

Focus on:

• Updated contracts with DPDP clauses
• Classification of vendors by data sensitivity
• Reviewing certifications
• Breach notification expectations

This reduces dependency risk immediately.

6. Build retention and deletion into systems

You’ll need:

• A definition of when a user becomes “inactive”
• Automated deletion or archival
• Alignment across teams on retention periods

This keeps unnecessary data from piling up.

7. Prepare for rights and grievance handling

Set up a simple workflow or portal to handle access, correction and deletion requests.
Train customer support and HR on how to handle them within the required timelines.

8. Get ahead of potential SDF classification

If you operate at scale or process sensitive categories, SDF status is likely.
Prepare for:

• Independent audits
• DPIAs
• A DPO structure

It is easier to warm-start than scramble later.

9. Build awareness across teams

Short, targeted training works best. Most compliance failures come from routine habits, not malice.

The Digital Personal Data Protection (DPDP) Act changes what India expects from organisations handling personal data. Compliance needs coordination across strategy, systems, and day-to-day habits. Done well, it improves trust and reduces long-term risk.

Privacy is no longer a legal checkbox; it’s a business competency that will influence how customers judge you.

Download DPDP Rules 2025 PDF