DPDP for the Software engineering department in BFSI

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.

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

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.

• Permission list with reasons
• App store listing
• Partner app review

• Contacts permission for 'reference checks'
• Third-party analytics SDKs collecting device data
• Partner apps not reviewed

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.

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

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.

• Clock page
• Templates
• Drill record

• Separate playbooks per regulator
• DPO told last
• No customer message template

Ask four questions at the design stage: what personal data, why, for how long, and who sees it. Then build in what the Act assumes: a notice, consent where needed, role-based access, logs of record views, a way to delete, and a way to answer requests. Adding these after launch costs far more.

Sections 5 to 12 assume systems that can show notices, record consent, limit access, log, delete and answer requests. Section 5 · Rule 3 · Section 6 · Section 8(5) · Rule 6 · Section 8(7) · Rule 8 · Sections 11–14 · Rule 14

1. Add the four questions to design templates.
2. Drop data you do not need.
3. Build access roles and record-view logs.
4. Build deletion and request export.
5. Register the system in the inventory at launch.

• Design review records
• Inventory entries
• Deletion tests

• Privacy review only at launch
• Collecting 'in case we need it'
• No delete function

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.

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

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

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.

• Backup retention settings
• Written backup-expiry rule
• Masking procedure for test data

• Ten-year backups for convenience
• Live copies in test
• Restoring old backups and bringing deleted records back

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.

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

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

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.

• Log source list
• Retention settings
• Alert review records

• 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

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.

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

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

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.

• Role matrix
• Quarterly review sign-offs
• Leaver removal report

• Generic logins on shared machines
• Access that only grows
• No review of vendor accounts

Anyone under 18 is a child under the Act. For a child's data you need verifiable consent from a parent or lawful guardian, and you must not track, behaviourally monitor or show targeted ads to children. Some classes and purposes are exempt under Rule 12 and the Fourth Schedule, for example healthcare to the extent needed to protect the child's health, and educational institutions for their educational work.

Minor savings accounts and student loans involve children's data. Parent consent and no targeted offers apply.

Section 9 sets the duties. Rule 10 explains how to verify the parent. Rule 12 and the Fourth Schedule list the exemptions. Section 9 · Rules 10, 12 · Section 6

1. Find where children's data enters: customers, dependants, interns, visitors, scholarships, app sign-ups.
2. Decide whether an exemption in the Fourth Schedule applies to that purpose.
3. Where none applies, add an age question and a parent-consent step.
4. Switch off tracking and targeted ads for under-18 users.
5. Record the decision for each channel.

• Channel-by-channel note on children's data
• Parent-consent records
• Ad and tracking settings

• Assuming 'we are B2B, so no children'
• Using the age 13 or 16 from foreign laws
• Treating a tick-box from the child as parental consent

You must erase data that you no longer need for the purpose it was collected for, unless a law requires you to keep it. Where a law does require it, keep the data, stop using it for anything else, and tell the person why it is being kept and until when.

Closed-account KYC and transaction records stay for the PMLA period; offers and profiling stop at once.

Section 12 gives the right to correction and erasure. Section 8(7) allows retention only where a law requires it. Rule 8(3) asks every organisation to keep personal data and logs for at least one year first. Sections 11–14 · Rule 14 · Section 8(7) · Rule 8

1. Log the request and verify identity.
2. Check the retention schedule for each record type involved.
3. Delete what has no legal reason to stay, including copies with vendors and in test systems.
4. Mark what must stay, with the law and the end date.
5. Reply in plain words: what was deleted, what is kept, why and until when.

• Erasure log
• Vendor deletion confirmations
• Reply to the person

• Refusing every erasure request 'because of backups'
• Deleting records a law requires
• Not telling vendors