Tool
Where a GDPR program needs separate DPDP review
A GDPR program is a head start, not a certificate. Each area below states the DPDP position from the primary sources and points at the official EUR Lex provisions to review on the GDPR side. This comparison is educational; it never concludes that compliance with one framework satisfies the other.
1. Breach notification
The DPDP position
Rule 7 reaches any personal data breach: every affected Data Principal is intimated without delay, and the Board gets a description without delay plus detailed information within seventy two hours. No risk threshold appears in the rule's text.
What to review on the GDPR side
Review your GDPR breach process under Articles 33 and 34 separately; do not assume its thresholds, recipients or timelines carry over.
2. Notices
The DPDP position
Rule 3 requires a standalone notice in clear and plain language with an itemised description of the personal data, the specified purposes and goods or services, and working paths to withdraw consent, exercise rights and complain to the Board.
What to review on the GDPR side
Review your GDPR privacy information under Articles 12 to 14 separately; a GDPR privacy policy is not automatically a Rule 3 notice.
3. Children's data
The DPDP position
The Act requires verifiable consent of the parent or lawful guardian before processing a child's personal data, prohibits processing likely to cause detrimental effect on a child's wellbeing, and prohibits tracking, behavioural monitoring and targeted advertising directed at children, with conditional exemptions. A child is anyone under eighteen.
What to review on the GDPR side
Review Article 8's age and consent model separately rather than assuming it mirrors the DPDP's eighteen year rule.
4. Retention and erasure
The DPDP position
Erasure is due on consent withdrawal or when the specified purpose is no longer served, unless retention is necessary for compliance with law, with prescribed time periods deeming purposes no longer served for prescribed classes; Rule 8 adds timed erasure with a forty eight hour warning and a one year floor for logs and associated data.
What to review on the GDPR side
Review storage limitation and erasure under Article 5(1)(e) and Article 17 separately; the DPDP's fixed log floor and warning mechanics must be built on their own terms, so do not assume those articles supply an equivalent.
5. Rights request machinery
The DPDP position
Data Principals get access to a summary of data, processing activities and sharing identities, correction, completion, updating and erasure, grievance redressal with a published response period not exceeding ninety days, and a right to nominate someone to exercise rights on death or incapacity.
What to review on the GDPR side
Review Articles 12 and 15 to 22 separately for scope and response timelines, and do not assume your GDPR rights tooling covers the nomination right.
6. Cross border transfers
The DPDP position
Transfers outside India are permitted subject to requirements the Central Government may specify by order for making data available to foreign states and entities under their control, and the government may restrict transfers to notified countries. Stricter Indian laws stay applicable.
What to review on the GDPR side
Review Chapter V (Articles 44 to 49) separately; do not map adequacy or standard clause reasoning onto the DPDP model.
7. Contact person and DPO
The DPDP position
Every Data Fiduciary must prominently publish the business contact of the Data Protection Officer if applicable, or a person able to answer processing questions, and repeat it in every rights response.
What to review on the GDPR side
Review your DPO arrangements under Articles 37 to 39 separately; the DPDP publication duty applies regardless of whether a GDPR style DPO exists.
8. Security safeguards
The DPDP position
Rule 6 lists minimum safeguards by name: encryption, obfuscation, masking or virtual tokens; access control; logs, monitoring and review; backups; one year retention of logs and data; processor contract provisions; and technical and organisational measures.
What to review on the GDPR side
Review Article 32 separately; map what it requires against Rule 6's named minimums item by item rather than assuming equivalence.
9. Impact assessments and audits
The DPDP position
Significant Data Fiduciaries, once notified as such, must undertake a Data Protection Impact Assessment and an audit every twelve months and report significant observations to the Board.
What to review on the GDPR side
Review Article 35 separately; the DPDP duty follows from being notified as significant, on an annual cycle, so check Article 35's own trigger conditions rather than assuming they align.
GDPR pointers cite the official EUR Lex text of Regulation (EU) 2016/679. This site does not restate GDPR requirements; read them at the source.