Data Protection Impact Assessment (DPIA) — DPDPA

Operational, defensible DPIAs under India’s Digital Personal Data Protection Act, 2023 (DPDPA) — aligned to Significant Data Fiduciary expectations and accountability by design.

Vibe Data Privacy™ by AMLEGALS is the bedrock of our DPIA practice: a privacy-by-design operating system that anchors purpose limitation, transparent notices and consent/legitimate uses, data minimisation, calibrated risk scoring, and grievance redressal into your product lifecycle—so DPDPA compliance is embedded, evidenced, and scalable across teams, vendors, and releases.

Privacy by Design Notice, Consent & Legitimate Uses Risk-Scored Controls
1

What Is a DPDPA DPIA?

A DPIA under the DPDPA is a structured assessment to identify, evaluate, and mitigate risks to Data Principals before and during processing. It connects purpose, notice & consent / legitimate uses, roles (Data Fiduciary / Processor), data flows, and controls to create an audit-ready record for internal governance and, where relevant, the Data Protection Board of India (DPBI).

2

Methodology (India)

A. Context & Scope

Define purposes; consent or legitimate uses; roles; geographies; data classes; retention; and map data flows & systems.

B. Risk Analysis

Score likelihood × impact for harms to Data Principals (exclusion, discrimination, surveillance, loss) and organizational risk.

C. Controls & Residual

Map technical, organizational, and contractual controls (incl. grievance redressal). Compute residual risk and decide proceed/defer.

3

Roles & Responsibilities (DPDPA)

Data Fiduciary

  • task_alt Determines purposes; ensures notice, consent/legitimate use, and compliance
  • donut_large Owns DPIA; approves residual risk; maintains records
  • support_agent If notified as SDF: appoint DPO, conduct audits as applicable

Processor / Vendors

  • handshake Process data per written contract and instructions
  • integration_instructions Provide system, data-flow, and safeguard details
  • description Support evidence collation for the DPIA pack
4

Illustrative Risk Heatmap

Calibrated scales (1–5) for likelihood and impact on Data Principals. Example only—project scores are evidence-driven.

1
2
3
4
5
Impact 5
H
H
C
C
C
Impact 4
M
H
H
C
C
Impact 3
L
M
H
H
C
Impact 2
L
L
M
H
H
Impact 1
L
L
L
M
M

Legend: L = Low, M = Medium, H = High, C = Critical. Residual risk is computed after mitigations and documented.

5

Deliverables & Evidence

DPIA Report Pack

  • article Executive summary & scope
  • travel_explore India-centric data flow & system map
  • rule Notice text; consent/legitimate use analysis
  • assessment Risk scoring, rationale & approvals

Control Set & Plan

  • vpn_lock Encryption, IAM, logging/monitoring
  • fact_check SOPs, training, grievance redressal
  • update Remediation timeline & owners

Audit-Ready Evidence

  • domain_verification Vendor diligence & contracts
  • dns Retention & deletion proofs; access logs
  • draw Design decisions & sign-offs
6

Sector-Specific Considerations

FinTech / BFSI

  • paid KYC flows & transaction monitoring
  • priority_high Profiling risk & bias checks
  • policy Strong records & retention controls

Health / MedTech

  • favorite Heightened safeguards in health contexts
  • science Pseudonymization & access segregation
  • local_hospital Vendor diligence for clinical tooling

SaaS / Platforms

  • cloud Multi-tenant access control & logging
  • transfer_within_a_station Sub-processor chains & contracts
  • public International data flows — safeguards & docs
7

DPIA Checklist Snapshot (DPDPA)

Design & Lawfulness

  • toggle_on Purpose mapped; consent/legitimate use identified
  • content_cut Collection & purpose limitation enforced
  • schedule Storage limitation & retention schedule
  • notifications_active Clear notices; rights & grievance

Security & Accountability

  • lock “Reasonable security safeguards” implemented
  • visibility Role-based access; audit logs
  • backup_table Breach response steps & records
  • assignment_ind Roles, training, approvals
8

Frequently Asked Questions (DPDPA)

Is a DPIA mandatory for every Data Fiduciary?

Not for all. It’s expected when notified as an SDF or where processing indicates significant risk. Many adopt DPIAs proactively to evidence accountability.

How long does a DPDPA DPIA take?

Typically 2–6 weeks depending on system complexity, vendor chains, and evidence readiness.

What if residual risk remains high?

We iterate controls, document rationale, and advise next steps consistent with the Act’s risk-based approach.

Can one DPIA cover multiple features?

Yes—use a master DPIA with addenda where purposes/datasets overlap to reduce duplication.

Start a DPDPA DPIA Discovery

To align scope, evidence needs, and a delivery plan tailored to your release timeline.

Get in Touch
 

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