DPDP for the Information security / SOC department in PSUs and utilities

Reviewed by InfraVeritas360 ResearchFirst published 10 October 2026Last reviewed 11 October 2026

Sources: DPDP Act, 2023 and DPDP Rules, 2025 (MeitY) · MeitY · CERT-In · NCIIPC · Central Electricity Authority

The SOC watches consumer systems, partner logins and, often, plant networks.

Written for: Information security / SOC department, Public sector undertakings and utilities. Open this seat in the interactive tool

What is different here

An incident may need a CERT-In report in six hours and notice to the DPO at once. Partner and township systems are often outside central monitoring.

The first four things to sort out

Bring partner and township systems under monitoring.
Watch partner and vendor accounts for bulk downloads.
Keep logs a year and ICT logs 180 days in India.
Rehearse the six-hour step with the DPO.

A worked example

Information security / SOC department

Bulk downloads from a franchisee login

21:40The SOC sees a collection franchisee login pull billing records for areas it does not serve.
22:00The login is disabled and logs are preserved.
01:30CERT-In is informed within six hours of noticing; the DPO is told at once.
Day 3The DPO sends the detailed report to the Data Protection Board within 72 hours.

Evidence kept

Alert
Timeline
CERT-In record
Board report

Partner logins need the same watch as staff logins.

What others in the sector usually do. Power utilities commonly use CEA guideline controls as the base for Rule 6 evidence.

Where it usually goes wrong, by organisation type

Organisation type	Hotspots
Oil and gas marketing	Distributor registers and delivery slips with addresses; Subsidy and Aadhaar data in distributor software; Consumer numbers shared with marketing partners
Power generation and transmission	Contract labour gate passes and biometrics; PSU hospital records of employees and families; Township allotment and resident records
Electricity distribution (state discoms)	Smart-meter data held by the meter vendor; Billing files shared with collection agencies; Consumer lists exposed on public bill lookup pages
Transport undertakings (rail PSUs, metro, state road transport)	Passenger lists and reservation charts; Concession passes with ID copies; CCTV and travel-card data
Steel, mining, defence production and heavy industry	Medical surveillance records of workers; Township and school records; Resettlement and compensation records of affected families
State development corporations and boards	Lottery and allotment lists published with full details; Ration and supply records; Old paper files in record rooms

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

DPDP duty	Law	NIST CSF 2.0	ISO/IEC 27001 Annex A	Evidence
Know where personal data is	Section 8(5) · Rule 6	ID.AM-02, ID.AM-07	5.9, 5.12	Inventory of systems and data types, with owner and hosting location
Only the right people get in	Section 8(5) · Rule 6	PR.AA-01, PR.AA-05	5.15, 5.16, 5.18, 8.2	Role matrix, quarterly access review sign-off, leaver removal report
Strong sign-in for admins and remote users	Section 8(5) · Rule 6	PR.AA-03	5.17, 8.5	MFA enforcement report for admin, VPN and email accounts
Encrypt or mask data	Section 8(5) · Rule 6	PR.DS-01, PR.DS-02	8.11, 8.24	Encryption settings for databases, laptops, backups and transfers; masking in test copies
Keep and watch logs	Section 8(5) · Rule 6	PR.PS-04, DE.CM-01, DE.CM-03	8.15, 8.16, 8.17	Log retention settings (one year; 180 days in India for CERT-In), alert rules, NTP source
Backups that restore	Section 8(5) · Rule 6	PR.DS-11, RC.RP-03	8.13, 5.30	Backup schedule, offline copy, last restore test with date and result
Separate networks	Section 8(5) · Rule 6	PR.IR-01	8.20, 8.22	Network diagram showing segments, firewall rule review
Patch and fix weaknesses	Section 8(5) · Rule 6	ID.RA-01	8.8	Vulnerability scan results and closure tracker
Handle incidents and tell people	Section 8(6) · Rule 7	RS.MA-01, RS.CO-02, RS.CO-03	5.24, 5.25, 5.26, 6.8	Incident plan with the 6-hour and 72-hour steps, drill record, contact list
Learn from incidents	Section 8(6) · Rule 7	DE.AE-02, ID.IM-01	5.27, 5.28	Post-incident review and actions closed
Vendors protect data too	Section 8(1)–(2)	GV.SC-05, GV.SC-07	5.19, 5.20, 5.22	Contracts with data terms, vendor review record
Data comes back or is deleted at contract end	Section 8(7) · Rule 8	GV.SC-10	5.20, 8.10	Exit clause and deletion certificate from the vendor
Cloud is set up safely	Section 16 · Rule 15	GV.SC-05, PR.DS-01	5.23	Cloud region list, shared-responsibility note, configuration review
Delete when the purpose is over	Section 8(7) · Rule 8	PR.DS-01	8.10, 7.14	Retention schedule, deletion log, disposal certificates for disks and paper
People know the rules	Section 8(5) · Rule 6	PR.AT-01	6.3	Training attendance and short test results by department
Legal duties are tracked	Section 8(5) · Rule 6	GV.OC-03	5.31, 5.34	Register of laws and rules that apply, reviewed yearly
Roles are named	Section 8(9)–(10) · Rules 9, 14	GV.RR-02	5.2, 5.4	Named owners for each system and each duty, approved by management

Logs, backups and access checklist

Logs. Access and activity logs for systems holding personal data are kept for at least one year (DPDP Rule 6 and Rule 8(3)).
Logs. ICT system logs are kept for 180 days, within India, as the CERT-In Directions of 28 April 2022 require.
Logs. System clocks are synced to the NTP servers of NIC or NPL, or to servers traceable to them, as CERT-In asks.
Clocks. Reportable cyber incidents can be reported to CERT-In within six hours of being noticed.
Clocks. Affected people and the Data Protection Board are told without delay, and the Board gets a detailed report within 72 hours.
Backups. At least one backup copy is offline or immutable, and a full restore was tested in the last six months.
Backups. Backup retention matches the retention schedule, so deleted records do not live on for years in old copies.
Access. Privileged and remote accounts use multi-factor sign-in.
Access. Access rights are reviewed every quarter, and leavers are removed on their last working day.
Access. Shared or generic logins are replaced with named accounts, or are tied to a named person in a register.
Vendors. Vendor remote access is named, time-bound and logged.
Test data. Test and training systems use masked data, not live copies.
OT separation. Personal-data systems are separated from plant and grid control networks.
Partner access. Distributor and franchisee logins are named, limited to masked views and logged.

9 questions the Information security / SOC department asks, answered in full

Townships, hospitals and schools run by the PSU: what applies?

Short answer: Yes, full duties for each service

These hold residents', patients' and students' data. Each needs a notice, access limits and retention. PSU hospital records follow medical record rules; school records may involve children, where Fourth Schedule exemptions for educational institutions and healthcare may apply to some purposes.

What the law says

Sections 5, 8(5), 8(7) and 9 apply to each service. Section 5 · Rule 3 · Section 8(5) · Rule 6 · Section 9 · Rules 10, 12 · Section 8(7) · Rule 8

Steps

List township services that hold personal data.
Give each a notice.
Restrict medical records.
Check children's data rules for schools.
Set retention.

Evidence to keep

Service list
Notices
Access settings

Common mistakes

Township PCs with no security
Medical records visible to HR
School data with no parent notice

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: Information security / SOC department. Start the CERT-In clock and tell the DPO at once.

Example in PSUs and utilities

A leaked consumer list from a distributor is your breach to report.

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

Name one incident lead and a back-up, with phone numbers that work at night.
Write the first-hour steps: isolate, preserve logs, tell the DPO and the incident lead.
Keep ready-made drafts for CERT-In, the regulator, the Board and affected people.
Decide in advance who signs off each message.
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

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: Information security / SOC department. One year of access logs, 180 days of ICT logs in India.

Example in PSUs and utilities

Consumer systems and township systems both need logging.

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

List systems holding personal data and what each logs today.
Turn on access logging where it is missing.
Send logs to one protected store, with at least one year of retention.
Keep a copy of ICT logs in India for at least 180 days.
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

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: Information security / SOC department. Watch privileged and vendor accounts.

Example in PSUs and utilities

Partner and franchisee logins are the weak point.

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

Write a role matrix for each key system.
Replace shared logins with named accounts.
Use multi-factor sign-in for admin and remote access.
Review access every quarter with each manager.
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

Does a security dashboard show privacy readiness?

Short answer: Only for the security part

Not by itself. A security dashboard shows alerts, patches and controls. It does not show whether notices were given, consent was recorded, requests were answered, vendors signed terms or data was deleted on time. Use it as evidence for the security duty only.

From your seat: Information security / SOC department. A green dashboard is not evidence of privacy readiness.

What the law says

Section 8(5) is one duty among many in Sections 5 to 12. Section 8(5) · Rule 6 · Section 5 · Rule 3 · Sections 11–14 · Rule 14

Steps

Map what the dashboard covers to Rule 6.
List the duties it does not cover.
Give those duties their own evidence.
Show both to management side by side.
Avoid one overall green status.

Evidence to keep

Coverage map
Evidence for other duties

Common mistakes

Reporting a green SOC dashboard as DPDP readiness
No owner for non-security duties
One colour for everything

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: Information security / SOC department. Test a full restore.

Example in PSUs and utilities

Backups of billing and ticketing systems follow retention.

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

List where copies live: backups, replicas, test, analytics, laptops, vendors.
Set backup retention to match the retention schedule.
Write a rule: deleted records are not restored into live systems.
Mask personal data in test and training copies.
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

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: Information security / SOC department. Monitor vendor access.

Example in PSUs and utilities

Distributors, franchisees, meter vendors, ticketing vendors and labour contractors.

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

List vendors who receive or can see personal data.
Rank them by how much and how sensitive.
Add a data-protection schedule to each contract, starting with the top ten.
Ask for evidence: certificates, test results, deletion confirmations.
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

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: Information security / SOC department. Data-loss rules help; reporting routes matter more.

Example in PSUs and utilities

Field and distributor groups share consumer lists on chat.

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

Ask teams how they actually share files and photos today.
Provide an approved tool for that job.
Set three simple rules: approved tool, no personal accounts, report wrong sends.
Teach the rules with real examples from your own work.
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

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: Information security / SOC department. Map controls once.

Example in PSUs and utilities

CEA guidelines and ISO 27001 cover much 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

Map your current controls to Rule 6.
Add the DPDP-only items: notice, consent, rights, complaints, children, retention.
Use the same evidence for audits and for DPDP.
Include privacy in the scope of your next internal audit.
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

The sections you will use most

Section 8(5) · Rule 6: Security safeguards. Large consumer systems and plant systems both need safeguards; some are protected systems.
Section 8(6) · Rule 7: Telling people about a breach.
Section 8(7) · Rule 8: Erasure and retention. If the State provisions do not apply to an activity, normal DPDP erasure applies after legal retention.

Other rules that sit alongside DPDP

Rule	What it says	What it means alongside DPDP	Source
DPDP Act, Section 2(x) and Article 12 of the Constitution	The Act defines 'State' with the meaning in Article 12. Many PSUs have been treated as 'the State' by courts, depending on government control.	Get a legal view on which activities can rely on Section 7(b), 7(c) and 17(4). Customer-facing commercial work usually follows full duties.	MeitY
CERT-In Directions, 2022	Report specified cyber incidents within six hours; keep ICT logs 180 days in India.	Applies to every PSU.	CERT-In
IT Act, Section 70 and NCIIPC	Systems notified as protected systems come under NCIIPC's critical information infrastructure framework.	Plant control, grid and pipeline systems may be notified; personal data in them follows DPDP too.	NCIIPC
CEA (Cyber Security in Power Sector) Guidelines, 2021	Cyber security requirements for power sector utilities, including incident reporting and supply chain controls.	Power PSUs and discoms can use this evidence for DPDP Rule 6.	Central Electricity Authority
Aadhaar Act, 2016	Aadhaar-linked subsidies such as LPG must store Aadhaar numbers securely and limit sharing.	Distributor systems and counters must not keep Aadhaar copies.	UIDAI
Labour Codes (in force from 21 November 2025)	Registers for workers and contract labour, health and safety records for hazardous work.	Set retention for worker and contract labour records against the codes and state rules.	Ministry of Labour
SEBI LODR Regulations (listed PSUs)	Listed PSUs follow disclosure and governance rules.	Board-level reporting on data protection fits into existing risk committee work.	SEBI
RTI Act, Section 8(1)(j) as amended	Personal information is exempt from RTI disclosure since 13 November 2025.	PSU CPIOs should apply the new wording with reasoned orders.	SFLC.in summary