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Home » Cyber Security News » Policy debate or execution challenge?, ETCISO

Policy debate or execution challenge?, ETCISO

Policy debate or execution challenge?, ETCISO

For any Indian enterprise, the latest set of policy directives around DPDP is akin to a hard reset. It’s a bold set of reforms with reports indicating an escalation in compliance costs – some indicating a 15% rise in operational expenses for advertising agencies. In comparison, another estimate predicts a 30% jump in compliance costs for multinational corporations. Irrespective of the operational adjustment, stiff financial penalties of up to Rs 250 crores have left boardrooms introspecting on ways to counter the latest disruption.

Setting priorities for “future compliance” sounds easy on paper. Still, it means the ever-vigilant CISOs and countless small and medium enterprises need to arm themselves with the one essential ingredient for every business quest: clarity.

DEALING WITH CHANGE

Achieving business clarity isn’t easy, considering data is everywhere – from sprawling, unstructured data estates (across cloud, on-premises, and archived state) to data scattered across SaaS tools and diverse vendor environments. As organisational data continues to grow, security becomes more nuanced and needs to answer these core questions: whose data, what data, where is the data, when was the data recorded, why was the data recorded, and how would it be used.

Dealing with change at this level may seem daunting to IT and legal teams, but the opportunities indicate ways and means to avoid the minefield. The DPDP framework does not demand perfection but does require intentionality. However, proving intentionality or intent is always subject to interpretation, and the concept of “reasonable security safeguards” varies across industries. This complexity requires understanding data sensitivity, relevance, and usage patterns before designing defences.

Hence, even as organisations begin the transition, interpretational gaps are likely to remain. For example, the requirement to report breaches within seventy-two hours is clear in intent, yet execution maturity may vary across sectors.

Banking and financial services have built these capabilities through earlier mandates; however, other sectors may still be formalising incident response playbooks, accountability structures, and forensic readiness. Cross-border data transfers present another area where additional clarity is expected. A straightforward interpretation is that organisations follow the best standards adopted by peers in the industry.

This may also be a pragmatic move to consider compliance at a global scale. Although there is no explicit criterion for approved jurisdictions; international, digitally distributed enterprises are likely to benefit from adopting flexible models. These practices include adopting stronger encryption, implementing contractual controls, implementing data segregation, and increasing regional processing to comply with local data residency laws.

Transition or A Switch?

Despite these uncertainties, the DPDP structure is not abrupt. The phased implementation approach recognises compliance as a journey rather than an on-off switch. Over the next year and a half, enterprises may find themselves in need of building or refining governance boards. There may also be an imminent need to ensure rights fulfilment mechanisms, strengthen consent processes, formalise documentation, and align audit practices. What makes such a transition different from traditional compliance exercises is the expectation that privacy and security must be embedded into everyday operations. It is not a paperwork requirement. It is a behavioural shift.

As enterprises work toward DPDP compliance, they can also use this moment to reevaluate how personal data moves across the organisation – from customer-facing apps and data lakes to SaaS platforms and on-premises analytical systems. Data exchange with vendors can be complex, but the transition is well worth the operational clarity and security gains.

There is another dimension that cannot be ignored: culture. Technology may make compliance measurable, but culture makes it sustainable.

DPDP places organisations in a position where employees, leadership teams, and partners must internalise a new mental model. This is one place where personal data is not merely an asset collected for convenience but a responsibility tied to trust. Developing such an enterprise mindset often takes longer than building any tool or framework.

The larger picture is encouraging – DPDP does not attempt to reinvent global norms but aligns India’s practice with international thinking, with ample room for enterprises to follow industry-driven standards. The Act is not a disruption for the sake of regulation, but a response to the scale of the digital world.

India now processes large volumes of personal data across various sectors, including healthcare, banking, logistics, fintech, and consumer technology. The law demands that this scale be matched with accountability. Compliance, therefore, is only a good starting point.

Organisations that view DPDP as a strategic shift, rather than a checkbox requirement, will be the ones that earn long-term trust and reap rewards from being responsible.

The author is Ruchin Kumar, VP-South Asia, Futurex.

Disclaimer: The views expressed are solely of the author and ETCISO does not necessarily subscribe to it. ETCISO shall not be responsible for any damage caused to any person/organization directly or indirectly.

  • Published On Jan 1, 2026 at 09:27 AM IST

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