Beyond ISO 27001: DPDP Compliance Gaps Your Audits Are Missing

Most security audits answer one question well: “Is data protected?”
Under DPDP, the question is no longer just “Are controls implemented?”

It becomes “Are you legally justified in collecting, using, retaining, and sharing this data at all?”

For many organizations, ISO 27001 certification has become a symbol of maturity. It signals that security controls are in place, risks are assessed, and processes are documented. Audits are passed. Certificates are renewed. Confidence grows.

But India’s Digital Personal Data Protection Act (DPDP Act) introduces a different kind of scrutiny.

At Infosprint Technologies, as we integrate DPDP into our cybersecurity auditing list, we identified a recurring “Compliance Illusion.” Organizations can remain ISO 27001–certified and still expose themselves to DPDP violations—simply because traditional audits were never designed to answer DPDP’s core accountability questions.

This is not a failure of ISO 27001. It’s a mismatch of intent.

The DPDP Rules 2025 Update: What You Need to Know

In November 2025, India crossed a significant regulatory milestone in data protection compliance by notifying the Digital Personal Data Protection Rules, 2025 (DPDP Rules) under the broader Digital Personal Data Protection Act, 2023, thereby operationalizing the DPDP framework for the first time.

1. Rules Now in Force

On 14 November 2025, the Ministry of Electronics & Information Technology (MeitY) formally notified the DPDP Rules, 2025, which set out detailed operational requirements for implementing the DPDP Act. 

• These Rules clarify how personal data must be collected, processed, stored, and protected.
  
• They establish obligations for data fiduciaries, consent managers, and the Data Protection Board of India.
  

This notification marks the full operationalisation of India’s first comprehensive digital privacy law after several months of consultations and stakeholder feedback.

2. Core Compliance Implications

The final Rules expand on provisions that businesses must factor into audit and governance models, including:

• Clear notice and consent requirements describing what data is collected and why.
• Breach notification duties with strict timelines (e.g., reporting to the Data Protection Board within 72 hours). 
• Data retention, erasure, and log retention expectations, such as minimum log retention periods and structured deletion workflows.
• Requirements for significant data fiduciaries, including annual audits and impact assessments.

These additions introduce data governance obligations that traditional ISO audit models do not currently address directly—especially in areas such as consent lifecycle, purpose-limit enforcement, and breach response.

3. Phased Implementation Timeline

While specific provisions of the Rules take effect immediately, others are scheduled to roll out over an 18-month phased compliance window.
This means organisations must begin aligning their systems and audits now, even as final implementation dates are set.

4. Wider Regulatory Context

Stakeholders — from multinational tech firms to local startups — are adjusting to this new regime, which enforces minimal data collection and stronger individual rights over personal data. This makes DPDP audit readiness a near-term priority for compliance teams across industries.

Aspect	DPDP Act, 2023	DPDP Rules, 2025	Implications for Organizations
Legal Framework	High-level statutory framework defining data protection principles, roles (Data Fiduciaries/Principals), rights, and obligations.	Detailed subordinate legislation that operationalizes the Act with specific procedures and compliance requirements.	Organizations now have actionable compliance items – not just legal obligations – to implement, document, and audit.
Consent Management	Requires lawful basis for processing and consent as a principle.	Provides explicit formats, standalone notice requirements, purpose statements, and mechanisms for withdrawal.	Consent must be granular, actionable, and auditable – tools and workflows may need updating to record withdrawal and notice metadata.
Operational Obligations	Act defines duties broadly (data protection, accuracy, security).	Rules specify timelines, phasing, and steps for compliance, including Consent Managers, breach notifications, and log retention.	Immediate compliance on some obligations; phased compliance on others. Planning and project phasing are now mandatory.
Breach Notification	Act envisages breach reporting duties in principle.	Detailed 72-hour breach notification process to Data Protection Board & data principals.	Security teams must align incident response workflows to DPDP breach timelines and evidence requirements – beyond internal security reporting.
Data Retention & Erasure	Mandates secure storage and lawful processing.	Establishes minimum retention periods, erasure workflows, and user notification prior to deletion.	Organizations must justify retention intervals and operationalize deletion processes linked to user rights and legal purpose.
Significant Data Fiduciaries (SDFs)	The concept exists under the Act.	Rules detail criteria for classification and enhanced obligations (annual DPIAs, audits, algorithmic transparency).	Larger entities must execute formal DPIAs, annual audits, and possibly privacy governance structures tailored to SDF status.
Data Transfers	Act outlines broad cross-border transfer principles.	Rules allow cross-border transfers with safeguards; government may specify permitted countries/mechanisms.	Multinational operations must align transfer mechanisms to the Rules’ conditions and implement appropriate contractual controls.
Phased Compliance Timelines	Structure and rights defined; implementation unspecified.	Rules implement a phased roll-out (immediate vs 12-month vs 18-month obligations).	Organizations should align project plans and audits with staged deadlines rather than treating compliance as a one-off effort.
Governance & Board	The Act created the Data Protection Board of India conceptually.	Rules clarify composition, process, and functioning of the Board.	Fines, adjudications, and DPDP disputes will now be managed by a defined authority, making readiness more predictable.

What ISO 27001 Was Designed to Do — and What It Wasn’t

ISO 27001 is fundamentally a security management standard. Its strength lies in structure and consistency.

Designed to Ensure:

• An Information Security Management System (ISMS) exists and is maintained
  
• Risks are identified and treated.
  
• Access to data is controlled.
  
• Incidents are detected, logged, and responded to
  
• Policies, procedures, and controls are documented and reviewed.

For Security Analysts, this maps cleanly to tooling, configuration, monitoring, and evidence collection.

However, ISO 27001 is intentionally agnostic to legal purposes.

Does Not Mandate:

• Why is personal data being collected in the first place
  
• Whether that purpose is lawful under DPDP
  
• Whether consent was valid, informed, and revocable
  
• Whether data retention aligns with the purpose limitation
  
• Whether individuals can exercise their legal rights over that data
  

ISO secures data. DPDP governs whether you should have that data at all—and for how long.

DPDP Changes the Question Auditors Ask

For GRC leaders, DPDP introduces a fundamental shift in audit philosophy.

Traditional audits focus on the existence and effectiveness of controls.
DPDP-focused assessments demand accountability and justification.

The framing changes:

• From: “Is access restricted?”
  To: “Is access restricted to data you are legally allowed to hold?”
  
• From: “Is data encrypted?”
  To: “Should this data still exist in your systems?”
  
• From: “Is the vendor compliant with security standards?”
  To: “Are you accountable for how that vendor processes personal data?”

DPDP doesn’t replace security audits—it sits above them, challenging assumptions they were never meant to test.

The Hidden DPDP Gaps ISO Audits Commonly Miss

This is where most organizations encounter blind spots.

1. Lawful Purpose Is Assumed, Not Proven

ISO audits typically assume data collection is legitimate if business processes exist. DPDP requires the opposite: organizations must demonstrate a lawful purpose for each category of personal data.

In practice, many teams cannot clearly explain:

• Why a specific data field exists
  
• Whether it is still required
  
• Whether its use aligns with the original collection intent

Assumptions pass audits. They do not satisfy DPDP.

2. Consent Is Treated as a Checkbox, Not a Lifecycle

Consent under DPDP is not a one-time banner or policy acceptance.

Audits rarely verify:

• Where consent records are stored
  
• Whether consent can be withdrawn
  
• Whether systems respect withdrawal
  
• Whether downstream systems stop processing data post-withdrawal

Security controls may be flawless, but DPDP evaluates behavior over time, not static configurations.

3. Retention Is Based on Convenience, Not Justification

ISO asks whether data is protected.
DPDP asks why it is still retained.

Common audit-safe answers like “for business needs” or “for future reference” fail DPDP scrutiny. Retention must be tied to:

• Legal obligation
  
• Explicit purpose
  
• Defined timelines
  

If retention logic cannot be defended, encryption does not help.

4. Third-Party Risk Stops at Contracts

Vendor security assessments often end with:

• SOC reports
  
• ISO certificates
  
• Signed DPAs

DPDP extends accountability further. As the Data Fiduciary, the organization remains responsible for:

• How processors use personal data
  
• Whether processing aligns with the stated purpose
  
• Whether breaches or misuse are detected and acted upon

Outsourcing processing does not outsource liability.

5. Incident Response ≠ DPDP Breach Obligations

Most incident response plans are written for operational recovery.

DPDP introduces additional expectations:

• Determining impact on data principles
  
• Assessing notification obligations
  
• Coordinating legal, compliance, and communication teams

An incident can be “handled” operationally and still fail DPDP requirements.

What This Looks Like in Real Audits

Across multiple assessments, the same patterns repeat:

• ISO-certified SaaS platforms with no consent withdrawal mechanisms
  
• HR systems are retaining former employee data indefinitely.
  
• Marketing databases secured and monitored—but collected without precise purpose mapping.
  
• Security logs are available, but there is no process to support data principal access or correction requests.
  

None of these fail traditional audits. All of them raise DPDP risk.

How Security Analysts Should Rethink Audit Readiness

For Security Analysts, DPDP does not mean abandoning existing controls. It means extending visibility and traceability.

Key shifts include:

• Moving from asset inventories to data flow mapping
  
• Tagging data by purpose, not just sensitivity
  
• Aligning retention controls with business justification
  
• Capturing evidence that explains why data exists, not just how it is protected

DPDP readiness is not about adding more tools.
It’s about making intent visible. Validate Your DPDP Control Coverage

How GRC Leads Should Extend Existing Audit Frameworks

For GRC leaders, DPDP requires integrating legal accountability into familiar frameworks.

Practical steps include:

• Mapping ISO 27001 clauses to DPDP obligations
  
• Adding DPDP checkpoints into internal audit programs
  
• Updating risk registers with DPDP-specific exposure.
  
• Preparing defensible narratives for regulators, customers, and partners
  

The goal is not parallel audits—but aligned governance.

ISO + DPDP: What a Mature Audit Model Looks Like

Mature organizations are already evolving toward a layered model:

• ISO 27001 establishes security discipline
  
• DPDP enforces lawful data accountability
  
• Continuous governance ensures alignment as systems and regulations evolve.

ISO remains foundational. DPDP reveals what foundations alone cannot cover.

Why Organizations Are Adding DPDP to Cybersecurity Audits Now

This shift is being driven by:

• Enterprise customer due diligence
  
• Procurement questionnaires
  
• Increased regulatory awareness
  
• Cross-border trust requirements

DPDP is no longer a future concern. It is becoming part of how trust is evaluated today.

Passing Audits Is No Longer the Finish Line

ISO 27001 certification remains valuable. But in a DPDP-driven environment, it is no longer sufficient. Security provides protection, and DPDP demands accountability.

The organizations that adapt early will not only reduce regulatory risk—they will also build credibility where it matters most.

The real question is no longer whether you are audited,
But whether your audits reflect today’s regulatory reality.

Whether you own security execution or compliance accountability, DPDP changes how audits are conducted.

The earlier gaps are identified, the easier they are to close. Start DPDP Reviewaling further..