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DPDP Checklist for Founders and Developers: From Data Map to Device Disposal

DPDP Checklist for Founders and Developers: From Data Map to Device Disposal

Founders and developers usually meet the DPDP Act through a privacy policy template. The Act asks for more than that, and the 13 May 2027 deadline for most obligations is closer than a typical product roadmap. This checklist is ordered the way a small team can work through it.

Know what you hold

  • List every place personal data lives: production databases, analytics, CRM, support tools, spreadsheets, backups, logs and laptops.
  • Note why you collect each field and whether you need it. Data you do not collect cannot leak.
  • Mark anything about children. Under the Act, anyone under 18 is a child and needs verifiable parental consent.

Build it in

  • Encrypt data at rest and in transit, and turn on full-disk encryption on every laptop.
  • Restrict access by role, and log access to personal data.
  • Keep logs and personal data for at least one year, as Rule 8(3) requires, then erase what you no longer need.
  • Build deletion that actually deletes, including from backups on a defined schedule.
  • Keep test and staging environments free of real personal data.

People, vendors and contracts

  • Every SaaS tool or contractor that touches personal data for you is a Data Processor. Put security terms in the contract, as Rule 6 expects.
  • Publish the business contact of a person who can answer privacy questions, as Rule 9 requires.
  • Publish your grievance process and a response time of no more than 90 days, as Rule 14 requires.
  • Offboard leavers the same day: accounts, tokens, devices.

When something goes wrong

  • Write down who decides a breach has happened, who informs affected users, and who informs the Data Protection Board.
  • Rule 7 expects notice without delay and a fuller report to the Board within 72 hours of becoming aware.
  • Practise it once. A lost laptop is a good scenario.

Retiring devices and systems

  • Keep a simple register of laptops, phones and servers, with who holds them.
  • When a device leaves, check retention first, then wipe with verification or destroy the drive.
  • Get a report per drive from whoever does it, and keep it with the register.
  • Do not sell company laptops to employees or buyers without a verified wipe.
  • When you shut down a cloud system, export what you must keep, then delete the rest and keep the deletion record.

If you need the last step done for you, certified data wiping gives you a report per drive, and small lots are fine.

Sources

Questions

Questions, answered.

Yes. It applies to any organisation processing digital personal data in India, whatever its size. Some obligations are heavier for Significant Data Fiduciaries, which the Government designates.

Only Significant Data Fiduciaries must appoint one. Everyone else must publish the business contact of a person who can answer questions about their processing.

At least one year from processing, under Rules 6 and 8(3), unless another law requires longer.

Wipe them with verified software or destroy the drives, and keep a report per drive with your device register.

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