Is being DPDP compliant enough?

As business leaders, we often find reassurance in statements like: “We are DPDP compliant” or “We passed our ISO/SOC audit.” However, the uncomfortable truth is that compliance does not equate to security.

Some of the largest cyber incidents, both globally and in India, have occurred in organizations that were fully compliant on paper. The Digital Personal Data Protection (DPDP) Act in India is a significant advancement, providing clarity on data fiduciary accountability, consent management, breach notification obligations, and imposing penalties totalling hundreds of crores. Yet, it's crucial to remember that DPDP is a legal framework, not a security architecture.

DPDP prompts the question: “Have you implemented reasonable safeguards?” but it does not inquire about:

• The speed of breach detection
• The ability to contain credential compromise
• The duration an attacker can dwell in your systems
• The business impact of customer data exfiltration

A DPDP policy document will not prevent ransomware, nor will a consent notice stop identity abuse. Many organizations find themselves in the Compliance Comfort Zone:

• Policies are approved
• Audits are passed
• Evidence is collected
• Leadership feels reassured

In the meantime:

• Identity remains the weakest link
• Logs exist but lack correlation
• Detection is delayed
• Response plans are untested

Attackers do not focus on compliance gaps; they exploit security gaps. Instead of merely asking, “Are we compliant?” we should consider:

• How quickly will we know if data is breached?
• Who currently has access to our most sensitive data?
• What actions will we take at 2 a.m. on a Sunday if credentials are compromised?
• Can we demonstrate containment rather than just documentation?
• Are our controls tested against real attack scenarios?

While compliance is necessary, security is essential for survival. The most resilient organisations:

• Use DPDP, ISO, and SOC as a baseline
• Build risk-based, threat-led security on top
• Assume breach

Compliance helps you pass audits. Security helps your business stay alive.
Audit-ready is good. Attack-ready is essential.