Who is required to appoint a Data Protection Officer under the DPDP Rules 2025?

Under Rule 10 of the DPDP Rules 2025, every organisation designated as a Significant Data Fiduciary by the Central Government under Section 10 of the DPDP Act 2023 must appoint a Data Protection Officer based in India. This typically applies to organisations that process large volumes of personal data, process sensitive personal data at scale, or operate in sectors with heightened data protection requirements.

What does a Data Protection Officer do under the DPDP Act?

A Data Protection Officer (DPO) acts as the point of contact for all data protection matters for a Significant Data Fiduciary. Key responsibilities include: managing Data Protection Impact Assessments (DPIAs) for high-risk processing, liaising with the Data Protection Board of India on complaints and inquiries, managing the breach notification process under Section 8(6), overseeing grievance redressal under Section 13, and conducting ongoing compliance health checks.

What is a Data Protection Impact Assessment (DPIA) and when is it required?

A Data Protection Impact Assessment (DPIA) is a structured process to identify and mitigate privacy risks associated with high-risk data processing activities. Under the DPDP Rules 2025, Significant Data Fiduciaries are required to conduct periodic DPIAs. A DPIA is particularly important before deploying new technologies, processing health or financial data at scale, processing children’s data, or implementing automated decision-making that significantly affects Data Principals.

Service

DPO Advisory

DPO-as-a-Service for Significant Data Fiduciaries. India-based Data Protection Officer with ongoing compliance support.

Who Needs a DPO

Under Rule 10 of the DPDP Rules, 2025, every Significant Data Fiduciary must appoint a Data Protection Officer based in India. A DPO is mandatory if you:

Are classified as a Significant Data Fiduciary by the Central Government (Section 10)
Process large volumes of personal data
Process sensitive personal data at scale
Operate in sectors with heightened data protection requirements

What's Included

India-Based DPO

Experienced DPO based in India as required by Rule 10. Acts as your point of contact for data protection matters.

DPIA Management

Data Protection Impact Assessment for high-risk processing activities. Identifies risks, proposes mitigations, and maintains documentation for Board inspection.

Board Liaison

Interface with the Data Protection Board of India on your behalf for complaints, inquiries, and breach notifications.

Breach Response

72-hour breach notification management. Incident assessment, Board notification, DP notification, evidence preservation, and post-incident analysis.

Ongoing Compliance Advisory

Regular compliance health checks, regulatory update briefings, policy reviews, training for your team, and proactive risk assessment.

Grievance Oversight

Manage grievance redressal process under Section 13. Ensure 90-day response SLA. Maintain grievance register and resolution records.

DPO Advisory

Who Needs a DPO

What's Included

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