DPO Under DPDPA: Do You Need One? What Are Their Responsibilities?
As the Digital Personal Data Protection Act (DPDPA), 2023 comes into effect, organizations operating in India must not only implement privacy controls, but also demonstrate governance and accountability in how personal data is processed. Central to this mandate is the appointment of a Data Protection Officer (DPO), a critical role for ensuring compliance and managing engagement with the Data Protection Board of India (DPBI).
But who exactly is a DPO under DPDPA? Do all organizations need one? How does this role integrate with existing governance roles like CISO, SPOC, or compliance leads?
Let’s break it down.
What Is a Data Protection Officer (DPO) Under DPDPA?
The DPDPA mandates that “Significant Data Fiduciaries” (SDFs) must appoint a Data Protection Officer. This individual is responsible for:
- Monitoring organizational compliance with DPDPA provisions
- Serving as the primary liaison with the Data Protection Board of India
- Managing data principal rights (access, erasure, grievance redressal)
- Overseeing internal training, assessments, and awareness
- Incident response and breach communication oversight
- Maintaining records of processing and ensuring lawful data handling practices
Do All Organizations Need a DPO
While the DPDPA explicitly requires DPOs for Significant Data Fiduciaries, the role is strongly recommended for all organizations processing sensitive personal data or operating in high risk sectors such as fintech, healthcare, or SaaS.
DPO vs. CISO vs. ISO SPOC: Who Does What?
In many organizations, especially those certified under ISO standards, roles such as:
- Chief Information Security Officer (CISO)
- ISO, SOC 2 Management Representative
- SPOC - Single Point of Contact
- IT Compliance Officer
…already exist. While there can be role overlaps, the DPO is legally accountable under DPDPA for privacy governance, unlike the CISO who typically focuses on cybersecurity and infrastructure resilience.
In smaller organizations, the CISO or SPOC can serve as the DPO if qualified provided there is no conflict of interest. In larger organizations, these are often distinct roles to maintain independence and accountability.
How ComplyPlanet Supports You: DPO as a Service
At ComplyPlanet, we provide DPO as a Service for organizations that:
- Lack internal privacy expertise
- Require an independent and qualified expert for governance
- Need a formal point of contact with the Data Protection Board of India
- Seek consistent oversight of data handling, grievance redressal, and compliance programs
Our service includes:
- Acting as your designated DPO for external and internal privacy matters
- Facilitating compliance assessments, DPIAs, and breach response
- Advising on contracts, vendor risk, and consent practices
- Keeping your board and leadership informed with regular compliance updates
Conclusion: Governance Starts With the Right People
As regulatory expectations grow, privacy is no longer just a legal checkbox, it’s a board level responsibility. The DPO plays a foundational role in making data protection operational, measurable, and credible.
Whether you’re scaling, seeking ISO 27001 certification, or aligning with global privacy laws, appointing a DPO is a strategic move, not just a legal one.
Let ComplyPlanet be your trusted privacy governance partner.
Contact us to explore our DPO as a Service model and ensure your organization is DPDPA ready responsibly, efficiently, and confidently.