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Banking, financial services and insurance

DPDP for the CISO / Security head in BFSI

You already run one of the most regulated security set-ups in the country. DPDP adds customer rights and one more reporting clock.

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What is different here

One incident may need a CERT-In report in six hours, a report to your regulator, and DPDP messages to customers and the Data Protection Board. The evidence you hold for RBI, SEBI or IRDAI audits is most of what DPDP needs.

The first four things to sort out

  1. Map controls once across your regulator's framework, CERT-In and DPDP.
  2. Build one incident playbook that runs every clock together.
  3. Check that payment and card data never sits outside India or in plain text in logs.
  4. Review agent, BC and partner access to customer data.

A worked example: A third-party API leaks customer names and balances

  1. 10:20The SOC sees unusual calls on a partner API. The partner's key is revoked and the endpoint closed.
  2. 13:40Logs show about 2,000 records exposed. The CISO informs the DPO and CERT-In before the six-hour mark.
  3. Same dayThe regulator is informed as its framework requires. The DPO sends the first note to the Data Protection Board.
  4. Day 3The detailed Board report goes in within 72 hours. Affected customers receive a plain message with what happened and what to watch for.

Evidence kept: SOC timeline; CERT-In acknowledgement; Regulator and Board submissions; Customer message.

Partner APIs need the same logging and kill switch as your own systems.

What others in the sector usually do. Most use their security operations centre and existing control library as the base, and add a privacy column to the incident playbook.

Where it usually goes wrong, by organisation type

Organisation typeHotspots
Scheduled commercial bankCross-selling insurance and mutual funds on account terms; Business correspondent devices and paper forms in villages; Old core banking archives with no deletion path
Co-operative bank (urban or rural)Vendor-run core banking with admin access from the vendor's office; Member and share registers kept on open shelves; Directors and staff who are also members and relatives of borrowers
NBFC and digital lenderApps asking for contacts, photos and call logs; Collection agents sharing borrower details with family or employers; Leads bought from aggregators with no consent record
Insurance company (life, general or health)Medical reports passed to TPAs and hospitals by email; Agent and broker access to policyholder data; Claims data kept long after the claim is closed
Broking, depository and wealthAuthorised persons with client lists on personal phones; Research-tip calls to people who never consented; Client KYC copies shared over email with partners
Payments and fintechCard numbers in logs and support tickets; Merchant onboarding documents in shared drives; Fraud models that use data beyond what users were told

Control map: DPDP to NIST CSF 2.0 and ISO/IEC 27001:2022

DPDP dutyLawNIST CSF 2.0ISO/IEC 27001 Annex AEvidence
Know where personal data isSection 8(5) · Rule 6ID.AM-02, ID.AM-075.9, 5.12Inventory of systems and data types, with owner and hosting location
Only the right people get inSection 8(5) · Rule 6PR.AA-01, PR.AA-055.15, 5.16, 5.18, 8.2Role matrix, quarterly access review sign-off, leaver removal report
Strong sign-in for admins and remote usersSection 8(5) · Rule 6PR.AA-035.17, 8.5MFA enforcement report for admin, VPN and email accounts
Encrypt or mask dataSection 8(5) · Rule 6PR.DS-01, PR.DS-028.11, 8.24Encryption settings for databases, laptops, backups and transfers; masking in test copies
Keep and watch logsSection 8(5) · Rule 6PR.PS-04, DE.CM-01, DE.CM-038.15, 8.16, 8.17Log retention settings (one year; 180 days in India for CERT-In), alert rules, NTP source
Backups that restoreSection 8(5) · Rule 6PR.DS-11, RC.RP-038.13, 5.30Backup schedule, offline copy, last restore test with date and result
Separate networksSection 8(5) · Rule 6PR.IR-018.20, 8.22Network diagram showing segments, firewall rule review
Patch and fix weaknessesSection 8(5) · Rule 6ID.RA-018.8Vulnerability scan results and closure tracker
Handle incidents and tell peopleSection 8(6) · Rule 7RS.MA-01, RS.CO-02, RS.CO-035.24, 5.25, 5.26, 6.8Incident plan with the 6-hour and 72-hour steps, drill record, contact list
Learn from incidentsSection 8(6) · Rule 7DE.AE-02, ID.IM-015.27, 5.28Post-incident review and actions closed
Vendors protect data tooSection 8(1)–(2)GV.SC-05, GV.SC-075.19, 5.20, 5.22Contracts with data terms, vendor review record
Data comes back or is deleted at contract endSection 8(7) · Rule 8GV.SC-105.20, 8.10Exit clause and deletion certificate from the vendor
Cloud is set up safelySection 16 · Rule 15GV.SC-05, PR.DS-015.23Cloud region list, shared-responsibility note, configuration review
Delete when the purpose is overSection 8(7) · Rule 8PR.DS-018.10, 7.14Retention schedule, deletion log, disposal certificates for disks and paper
People know the rulesSection 8(5) · Rule 6PR.AT-016.3Training attendance and short test results by department
Legal duties are trackedSection 8(5) · Rule 6GV.OC-035.31, 5.34Register of laws and rules that apply, reviewed yearly
Roles are namedSection 8(9)–(10) · Rules 9, 14GV.RR-025.2, 5.4Named owners for each system and each duty, approved by management

Logs, backups and access checklist

10 guides for the CISO / Security head, in full

One incident, many regulators: how do we meet every clock?

Short answer: Six hours for CERT-In; regulator as its rules say; DPDP without delay and 72 hours

Most BFSI incidents need a CERT-In report within six hours, a report to your regulator as its rules require (IRDAI asks within 24 hours of the CERT-In report), and DPDP messages to customers and the Data Protection Board without delay, with a detailed Board report in 72 hours. One playbook with one timeline avoids missed steps.

From your seat: CISO / Security head. You start the clocks; keep the timeline evidence.
What the law says

Section 8(6) and Rule 7 set the DPDP steps. CERT-In and your regulator set the others. Section 8(6) · Rule 7 · Section 8(5) · Rule 6

Steps
  1. Put every clock on one page.
  2. Name who files each report.
  3. Keep templates ready.
  4. Rehearse with all filers present.
  5. Log the time each report went.
Evidence to keep
  • Clock page
  • Templates
  • Drill record
Common mistakes
  • Separate playbooks per regulator
  • DPO told last
  • No customer message template
Related questions

What can our lending or banking app collect from a phone?

Short answer: Need-based only, with explicit consent

Only what you need, with explicit consent. RBI's Digital Lending Directions already bar access to contacts, files, media and call logs, and allow one-time access to camera, microphone or location for onboarding or KYC. DPDP adds a notice, the right to withdraw and the right to know what was collected.

From your seat: CISO / Security head. Test the app for data leaks in logs and storage.
What the law says

Section 6 needs consent limited to what is necessary. RBI's Digital Lending Directions, 2025 set specific limits. Section 6 · Section 5 · Rule 3 · Section 8(5) · Rule 6

Steps
  1. List every permission the app asks for.
  2. Remove permissions not needed.
  3. Ask camera and location only at the KYC step.
  4. Show the notice in the app before sign-up.
  5. Check partner apps the same way.
Evidence to keep
  • Permission list with reasons
  • App store listing
  • Partner app review
Common mistakes
  • Contacts permission for 'reference checks'
  • Third-party analytics SDKs collecting device data
  • Partner apps not reviewed
Related questions

Something has gone wrong. What happens in the first 72 hours?

Short answer: Six hours for CERT-In; without delay for people and the Board; 72 hours for the detailed report

Contain it, then tell people. A reportable cyber incident goes to CERT-In within six hours of being noticed. Under DPDP, each affected person and the Data Protection Board must be told without delay, and the Board needs a detailed report within 72 hours. Sector regulators may have their own clock too.

From your seat: CISO / Security head. You start the six-hour CERT-In clock and feed the DPO what is needed for the people and Board messages. Keep the timeline evidence: who saw what, and when.
In BFSI

A partner API leak may need CERT-In in six hours, your regulator's report, and the DPDP messages.

What the law says

Section 8(6) and Rule 7 set the DPDP steps. The CERT-In Directions of 28 April 2022 set the six-hour report. A breach includes accidental disclosure and loss of access, not only hacking. Section 8(6) · Rule 7 · Section 8(5) · Rule 6

Steps
  1. Name one incident lead and a back-up, with phone numbers that work at night.
  2. Write the first-hour steps: isolate, preserve logs, tell the DPO and the incident lead.
  3. Keep ready-made drafts for CERT-In, the regulator, the Board and affected people.
  4. Decide in advance who signs off each message.
  5. Rehearse once a year with the people who would actually be called.
Evidence to keep
  • Incident plan with clocks
  • Rehearsal record
  • Incident log with times of each step
Common mistakes
  • Waiting to finish the investigation before telling anyone
  • Treating a wrong email or a lost laptop as 'not a breach'
  • Only IT knowing the plan
Related questions

Which logs must we keep, for how long, and where?

Short answer: At least one year; 180 days of ICT logs in India

Keep logs that show who accessed personal data and what they did, for at least one year under the DPDP Rules. CERT-In separately asks for ICT system logs to be kept for 180 days within India. Logs must be protected so nobody can quietly change them.

From your seat: CISO / Security head. Check retention on every log source against one year, and make sure ICT logs stay in India for 180 days. Logs that can be edited by the admins they record are weak evidence.
In BFSI

Core banking, internet banking and card systems already log heavily. Check retention and that logs stay in India.

What the law says

Rule 6 lists logs and monitoring as a minimum safeguard. Rule 8(3) asks for logs to be kept for at least one year. The CERT-In Directions of 2022 ask for 180 days of ICT logs kept within India. Section 8(5) · Rule 6 · Section 8(7) · Rule 8

Steps
  1. List systems holding personal data and what each logs today.
  2. Turn on access logging where it is missing.
  3. Send logs to one protected store, with at least one year of retention.
  4. Keep a copy of ICT logs in India for at least 180 days.
  5. Sync clocks and review alerts every day.
Evidence to keep
  • Log source list
  • Retention settings
  • Alert review records
Common mistakes
  • Logging only failures, not who viewed a record
  • Logs stored on the same server they describe
  • Clocks out of sync, so timelines cannot be built
Related questions

Who should be able to see personal data in our systems?

Short answer: Only those who need it, reviewed every quarter

Only people who need it for their job, and only the part they need. Use named accounts, give access by role, review it every quarter and remove it on the day someone leaves. Watch privileged accounts closely.

From your seat: CISO / Security head. Prioritise privileged and remote access. One review of admin accounts across core systems usually finds the biggest gaps.
In BFSI

Mark staff and VIP accounts so only a small team can view them.

What the law says

Rule 6 names access control as a minimum safeguard, along with logs and monitoring that can detect misuse. Section 8(5) · Rule 6

Steps
  1. Write a role matrix for each key system.
  2. Replace shared logins with named accounts.
  3. Use multi-factor sign-in for admin and remote access.
  4. Review access every quarter with each manager.
  5. Remove access on the last working day.
Evidence to keep
  • Role matrix
  • Quarterly review sign-offs
  • Leaver removal report
Common mistakes
  • Generic logins on shared machines
  • Access that only grows
  • No review of vendor accounts
Related questions

Does deletion have to reach backups and test copies?

Short answer: Yes, through a written backup-expiry rule

Deletion should reach every copy you control. For backups, the usual practice is to let deleted records expire with the normal backup cycle, never restore them into live use, and write this down. Test and training copies should use masked data.

From your seat: CISO / Security head. Test a full restore, not a file restore. Then check that backup retention does not quietly keep deleted records for years.
In BFSI

Core banking backups often run for years. Match backup retention to the record schedule.

What the law says

Section 8(7) asks for erasure. Rule 6 asks for backups for continuity. The two meet in a backup retention rule that is short enough and written down. Section 8(7) · Rule 8 · Section 8(5) · Rule 6

Steps
  1. List where copies live: backups, replicas, test, analytics, laptops, vendors.
  2. Set backup retention to match the retention schedule.
  3. Write a rule: deleted records are not restored into live systems.
  4. Mask personal data in test and training copies.
  5. Get deletion confirmations from vendors.
Evidence to keep
  • Backup retention settings
  • Written backup-expiry rule
  • Masking procedure for test data
Common mistakes
  • Ten-year backups for convenience
  • Live copies in test
  • Restoring old backups and bringing deleted records back
Related questions

What must a vendor contract say about personal data?

Short answer: Yes, every vendor that touches personal data

You stay responsible for what your vendors do with personal data. The contract should say what data they get, for what purpose, the security they must keep, how fast they must tell you about an incident, that sub-contractors need your approval, and how data is returned or deleted at the end.

From your seat: CISO / Security head. Set the technical schedule: incident notice in hours, logging, MFA, sub-contractor approval. Ask for evidence once a year.
In BFSI

Collection agencies, BCs, DSAs, KYC vendors, card processors and the core banking vendor all need data schedules aligned with RBI outsourcing rules.

What the law says

Section 8(1) keeps responsibility with you. Section 8(2) allows a processor only under a valid contract. Rule 6 asks for security terms in that contract. Section 8(1)–(2) · Section 8(5) · Rule 6 · Section 8(6) · Rule 7 · Section 8(7) · Rule 8

Steps
  1. List vendors who receive or can see personal data.
  2. Rank them by how much and how sensitive.
  3. Add a data-protection schedule to each contract, starting with the top ten.
  4. Ask for evidence: certificates, test results, deletion confirmations.
  5. Review the top vendors every year.
Evidence to keep
  • Vendor register
  • Signed data-protection schedules
  • Annual review notes
Common mistakes
  • Relying on the vendor's standard terms
  • No incident-notice time
  • No exit and deletion clause
Related questions

Can personal data be stored or accessed outside India?

Short answer: Yes, unless a sector rule says otherwise

Under DPDP, yes, unless the government restricts a country, and none had been restricted when this page was last reviewed. A sector rule can be stricter, for example RBI's rule that payment system data must be stored only in India. Remote support access from abroad also counts as data going outside India.

From your seat: CISO / Security head. Look at where admins and support staff log in from, not only where servers sit. Overseas support access is a transfer.
In BFSI

Payment system data must be stored only in India. Check overseas support access to core systems.

What the law says

Section 16 allows transfers unless restricted, and keeps stricter sector laws in force. Rule 15 adds conditions on making data available to foreign states. Section 16 · Rule 15 · Section 8(1)–(2)

Steps
  1. List where each system is hosted and where support teams log in from.
  2. Check sector rules for localisation.
  3. Put location and access terms in cloud and vendor contracts.
  4. Keep the list current; new SaaS tools change it quietly.
  5. Tell people in your notice if data goes abroad.
Evidence to keep
  • Hosting and access-location list
  • Contract clauses
  • Sector rule check
Common mistakes
  • Forgetting email, CRM and helpdesk SaaS
  • Ignoring overseas support logins
  • Assuming 'Indian vendor' means 'data in India'
Related questions

Staff share personal data on WhatsApp and personal email. What do we do?

Short answer: Yes, this is a common breach; give staff a safer option

Sending personal data to the wrong chat or a personal account is one of the most common breaches. Banning messaging rarely works. Give staff an approved tool that is easy to use, set simple rules, and make it safe to report a wrong send at once.

From your seat: CISO / Security head. Your tooling can help: data-loss rules on email, an approved file-share, mobile device controls. Pair it with a reporting route that people trust.
In BFSI

Relationship managers share lead lists and statements on chat. Give them a CRM route.

What the law says

Section 8(5) asks for reasonable safeguards. A wrong send is a breach under Section 2(u), and Section 8(6) applies. Section 8(5) · Rule 6 · Section 8(6) · Rule 7

Steps
  1. Ask teams how they actually share files and photos today.
  2. Provide an approved tool for that job.
  3. Set three simple rules: approved tool, no personal accounts, report wrong sends.
  4. Teach the rules with real examples from your own work.
  5. Treat a quick report as good behaviour, not a disciplinary case.
Evidence to keep
  • Approved-tool policy
  • Training record
  • Incident reports of wrong sends
Common mistakes
  • A ban with no alternative
  • Punishing people who report
  • Ignoring group chats with vendors
Related questions

Does ISO 27001 or NIST CSF cover our DPDP duties?

Short answer: They cover security, not the whole Act

They help a great deal with the security part. ISO/IEC 27001 and NIST CSF 2.0 are good evidence of reasonable security safeguards. They do not cover notice, consent, rights, complaints or children's data. ISO/IEC 27701 adds privacy controls, but no certificate replaces the Act.

From your seat: CISO / Security head. Use the control map below. Most of Rule 6 is already in your ISO or NIST work; the job is to collect the evidence in one place.
In BFSI

RBI, SEBI and IRDAI frameworks plus ISO 27001 cover most of Rule 6.

What the law says

Section 8(5) and Rule 6 ask for reasonable security safeguards. A recognised standard is strong evidence of that duty, and only of that duty. Section 8(5) · Rule 6

Steps
  1. Map your current controls to Rule 6.
  2. Add the DPDP-only items: notice, consent, rights, complaints, children, retention.
  3. Use the same evidence for audits and for DPDP.
  4. Include privacy in the scope of your next internal audit.
  5. Consider ISO/IEC 27701 if clients ask for it.
Evidence to keep
  • Control map
  • Audit reports
  • Gap list for DPDP-only items
Common mistakes
  • Treating a certificate as DPDP compliance
  • Scope that leaves out the systems with the most personal data
  • No owner for the non-security duties
Related questions

Practical examples

Notice wording, request log, retention schedule, vendor clause and breach notice for banking, financial services and insurance.

The sections you will use most

Other rules that sit alongside DPDP

RuleWhat it saysWhat it means alongside DPDPSource
Prevention of Money-laundering Act, 2002 and RBI KYC Master Direction, 2016Keep transaction records for at least five years from the transaction, and identity records for at least five years after the relationship ends.These periods override an erasure request. Explain the retention to the customer and stop every other use.RBI KYC Master Direction
RBI Master Direction on IT Governance, Risk, Controls and Assurance Practices, 2023In force from 1 April 2024 for commercial banks, larger NBFCs, credit information companies and all-India financial institutions. Requires IT governance under the board, audit trails, logging and incident reporting to CERT-In and RBI.Most of the DPDP security duty is already here. Map controls once and use the evidence for both.RBI
RBI Master Direction on Outsourcing of IT Services, 2023The regulated entity stays responsible for outsourced IT, with contracts, audit rights and exit plans.Line up DPDP processor contracts with this direction, so one schedule meets both.RBI
RBI direction on storage of payment system data, 2018All data relating to payment systems must be stored only in India.This is stricter than DPDP Section 16, and it continues to apply.RBI
RBI rules on card storage and tokenisation (from 1 October 2022)Only card issuers and card networks may store actual card data. Others use tokens, created with the cardholder's explicit consent.Check logs, call recordings and support tickets for card numbers.RBI
RBI (Digital Lending) Directions, 2025Collect only need-based data with prior explicit consent and an audit trail. Apps should not access contacts, files, media or call logs; one-time access to camera, microphone or location is allowed for onboarding or KYC with consent.Your app permissions and lending partner contracts are where DPDP and RBI meet.RBI
IRDAI Information and Cyber Security Guidelines, 2023Report cyber incidents to CERT-In within six hours, and to IRDAI within 24 hours of the CERT-In report.One incident plan should run the CERT-In, IRDAI and Data Protection Board steps together.IRDAI
SEBI Cybersecurity and Cyber Resilience Framework (CSCRF), 2024Security, logging and incident-reporting duties for SEBI-regulated entities. Stock brokers and depository participants report cyber incidents within six hours.Use CSCRF evidence for DPDP security, then add notices, consent and rights.SEBI
CERT-In Directions, 28 April 2022Report specified cyber incidents within six hours. Keep ICT logs for 180 days within India. Sync clocks to Indian time sources.Applies to every BFSI entity in addition to the regulator's own clock.CERT-In
Credit Information Companies (Regulation) Act, 2005Governs what credit information is shared with credit bureaus and how errors are corrected.Credit bureau sharing has its own law; DPDP rights requests about bureau data should point to that process too.Act
RBI Integrated Ombudsman Scheme, 2021Customers can escalate unresolved complaints to the RBI Ombudsman.Privacy complaints may reach both the Ombudsman and the Data Protection Board. One complaint log helps.RBI
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