Module 9 · DPIA — Data Protection Impact Assessment Under DPDP

Manish Garg
Manish Garg Associate of (ISC)² · RingSafe
Apr 27, 2026
3 min read
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Last updated: April 29, 2026

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Why this module exists. §10(2)(c) requires Significant Data Fiduciaries (SDFs) to conduct DPIAs. The Rules (when published) will likely extend DPIA expectations to high-risk processing by all Data Fiduciaries. Most Indian businesses have never done one. The methodology is more practical than the legal text suggests.

Why this module exists. §10(2)(c) requires Significant Data Fiduciaries (SDFs) to conduct DPIAs. The Rules (when published) will likely extend DPIA expectations to high-risk processing by all Data Fiduciaries. Most Indian businesses have never done one. The methodology is more practical than the legal text suggests.

What a DPIA is

A structured assessment of a processing activity:

  1. What data do you process, why, how?
  2. Is the processing necessary and proportionate?
  3. What risks does it pose to data principals?
  4. What mitigations bring the risks to acceptable levels?
  5. What residual risk remains?

Output: a document. Reviewed periodically. Available to the regulator on request.

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