After all the discussion around it, one would expect leadership teams to have a firm understanding of the Digital Personal Data Protection Act (DPDPA). Yet, across industries, we continue to hear statements that simply do not align with what DPDPA stands for. These myths are not harmless; they delay implementation, weaken security posture, and increase the organisation’s exposure to penalties levied by the Data Protection Board of India.
Here are the six most common myths. Wait until you see the sixth!
Myth 1: DPDPA is the compliance team’s responsibility.
Reality: Data protection under DPDPA impacts multiple functions across an organisation: while the compliance team can interpret the law, every function that touches personal data is a data steward responsible for lawful processing, purpose limitation, and data minimization within their domain. Technology teams are responsible for the systems that process personal data and for implementing access controls and security measures; HR and administration handle employees’ and contractors’ personal data; and the procurement team manages vendors’ contracts. DPDP compliance is not just a department’s job, it is an organization-wide responsibility.
A practical way to implement this is following a hub-and-spoke model:
- Hub (Central): Compliance team/DPO defines policies, provides training, and oversees audits.
- Spokes (Distributed): Each department owns their data practices, implements controls, and reports compliance status.
Leave privacy to one team, and you leave the entire organisation exposed.
Myth 2: We don’t collect much personal data.
Reality: Most organisations collect far more personal data than they realise. This includes customer contact details stored in CRM systems, IP addresses captured in analytics logs, KYC records of contractors, personal data of employees maintained in HRMS platforms, and, in many cases, biometric data such as facial recognition or fingerprints. Not all such data is necessary; its relevance depends on the business and purpose of the organisation.
The real issue is not volume, it is visibility. Without robust data discovery and adequate data mapping, organisations will struggle to implement DPDPA.
You cannot protect the data you cannot see.
Myth 3: We’ll worry about breach notifications if something goes wrong.
Reality: As per the DPDP Rules, organisations have just 72 hours to inform the Data Protection Board of a breach. However, the obligation does not end with the notification; organisations must also demonstrate that reasonable safeguards existed before the incident occurred. This requires proactive detection, DPDPA-aligned SIEM monitoring, breach severity classification, defined escalation procedures, and a well-prepared Data Protection Officer.
Documented evidence of consent management, security controls, employee training, and vendor oversight become critical during incident response. Many incidents originate from outdated or legacy systems, further complicating compliance.
If you plan to address breach notifications later, you are already behind.
Myth 4: Consent fixes everything.
Reality: Consent is not a solution by itself; it is only the starting point. Even with valid, well-recorded consent linked to a specified and lawful purpose, organisations must enforce data retention rules, comply with data erasure requests, implement security safeguards and grievance redressal mechanisms, and ensure verifiable parental consent for children’s data.
Treat consent as permission to begin, not permission to relax.
Myth 5: DPDPA is a one-time project.
Reality: DPDPA compliance is not a one-time exercise. It requires ongoing governance supported by periodic audits, evolving vendor contracts, and continuous risk assessments. The DPDP Rules mandate annual Data Protection Impact Assessments (DPIAs) and audits, along with the retention of relevant logs for at least one year. As systems evolve, integrations expand, and data flows change, the risk surface grows.
Organisations classified as Significant Data Fiduciaries face even stricter oversight and must maintain continuous monitoring and documentation.
DPDPA is not a project, it is an operating discipline.
Myth 6: Our vendors will handle their part.
Reality: This is the most damaging misconception. Vendors often operate with outdated agreements, ambiguous breach responsibilities, excessive access rights, or unstructured deletion processes. A detailed RACI matrix can help distribute responsibilities clearly; however, under DPDPA, ultimate accountability rests with you, the data fiduciary.
Robust vendor risk management, updated contracts, and regular due-diligence checks are essential. Many compliance failures arise from third-party lapses, not internal ones.
Your vendors process the data. You own the consequences.
In conclusion, by busting these myths, organisations will be able to use compliance as a genuine strategic advantage. As we prepare to enter a new year, this is the perfect time to reset, rethink, and gear up for a stronger, privacy-prioritized 2026.
DPDPA is not complicated, our assumptions about it are.
