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CERT-In Empanelled — Empanelled since 2008 — one of India's longest-standing security auditors

GDPR and DPDP Act Compliance for Indian Enterprises

Go beyond policy documentation. Security Brigade delivers technical data protection compliance — mapping data flows from code and infrastructure, testing controls, and achieving dual GDPR and DPDP Act readiness for India-to-EU operations.

DPDP + GDPR
Privacy Frameworks
Privacy by Design
Methodology
6,700+
Assessments
Since 2008
CERT-In Empanelled

Trusted by India's leading enterprises

ICICI Bank
NPCI
HDFC
Mahindra
Aditya Birla
PhonePe
Pernod Ricard
Swiggy
Asian Paints
Yes Bank
Tata Play
Larsen & Toubro
Voltas
DHL Express
Etihad Airways
Amazon Pay
Go Digit
Pharmeasy
BillDesk
Jubilant Foods
UltraTech
Titan
Infosys
Capgemini
Groww
Sephora
STEP 01

Assess

We map your data flows from code and infrastructure, identify personal data processing activities, evaluate technical controls, and benchmark your current posture against GDPR and DPDP Act requirements. This includes automated discovery of data stores, cross-border transfer mechanisms, and consent management implementations.

STEP 02

Remediate

Based on the gap analysis, we provide a prioritized remediation roadmap with specific technical guidance. Our team works alongside your developers and infrastructure teams to implement privacy-by-design controls, data minimization mechanisms, encryption standards, and access controls that satisfy both GDPR and DPDP Act mandates.

STEP 03

Certify

After remediation, we conduct validation testing to confirm all controls meet regulatory requirements. You receive a formal compliance assessment report, a compliance readiness certificate, and ongoing support for maintaining compliance during regulatory changes, audits, or Data Protection Board inquiries.

What Are GDPR and the DPDP Act?

The General Data Protection Regulation (GDPR) is the European Union's data protection law governing how organizations collect, process, and store personal data of EU residents. India's Digital Personal Data Protection Act 2023 (DPDP Act) is India's equivalent framework, establishing obligations for data fiduciaries processing Indian citizens' personal data. Organizations operating across India and Europe must comply with both regulations simultaneously.

Who Needs GDPR and DPDP Act Compliance?

Both regulations have broad applicability — if you process personal data, you likely fall within scope.

BFSI and Financial Services

Banks, NBFCs, insurance companies, and fintech firms processing customer KYC, transaction, and financial data under both Indian and international data protection obligations.

SaaS and Technology Companies

Software platforms with users or customers in the EU and India, especially those processing behavioral data, user analytics, or automated decision-making outputs.

Healthcare and Pharma

Organizations handling patient records, clinical trial data, telemedicine information, and health data subject to heightened sensitivity classifications under both GDPR and DPDP.

E-Commerce and Retail

Online and omnichannel retailers collecting customer data, payment information, delivery addresses, and behavioral tracking data across Indian and European markets.

Manufacturing and Industrial

Enterprises with employee data across jurisdictions, vendor management systems, customer portals, and IoT devices collecting personal or operational data.

Companies with India-EU Data Flows

Any organization transferring personal data between India and the EU, including IT services companies, BPOs, shared service centers, and global delivery organizations.

AI and Automated Decision-Making

Organizations using AI systems for profiling, scoring, or automated decisions affecting individuals. Both GDPR Article 22 and DPDP Act provisions require transparency and safeguards.

Significant Data Fiduciaries

Organizations designated as Significant Data Fiduciaries under the DPDP Act face additional obligations including mandatory Data Protection Impact Assessments and periodic audits.

Methodology

6 stages. Audit-ready results.

Every engagement follows this process through Lemon, our proprietary audit management platform.

Most compliance consultants review policies and generate checklists. Security Brigade takes a fundamentally different approach — we assess technical controls at the code and infrastructure level, map actual data flows through your systems, and validate that privacy mechanisms work as intended. Our India-specific methodology addresses the unique requirements of the DPDP Act 2023 while maintaining alignment with GDPR for organizations operating across both jurisdictions.

Discovery
01

Discovery and Data Mapping

We begin with comprehensive discovery of your data ecosystem. This includes automated scanning of databases, APIs, cloud storage, and application code to identify where personal data resides, how it flows between systems, and where it crosses geographical boundaries. We map consent collection mechanisms, data retention implementations, and access control architectures. This is not a questionnaire-based exercise — we examine actual infrastructure and codebase.

02

Gap Assessment Against Both Frameworks

Using the data map as foundation, we perform a detailed gap analysis against GDPR articles and DPDP Act provisions simultaneously. We evaluate technical safeguards including encryption at rest and in transit, pseudonymization implementations, access controls, data minimization practices, and automated decision-making transparency. Each gap is categorized by regulatory criticality, business impact, and remediation complexity.

Testing
03

Technical Control Testing

We go beyond documentation review to test whether your data protection controls actually work. This includes penetration testing of privacy mechanisms, testing consent withdrawal flows end-to-end, validating data deletion and anonymization routines, verifying cross-border transfer safeguards, and testing access controls around personal data stores. Our L1/L2/L3 review process ensures thoroughness.

04

AI System Compliance Assessment

For organizations using AI and automated decision-making, we evaluate compliance with GDPR Article 22 requirements and DPDP Act provisions on automated processing. This covers transparency of AI logic, human-in-the-loop mechanisms, bias assessment, data minimization in training datasets, and documentation of automated decision-making impacts on data subjects.

Delivery
05

Remediation Roadmap and Implementation Support

We deliver a prioritized remediation roadmap with specific technical guidance for your development and infrastructure teams. Recommendations include code-level fixes, configuration changes, architecture modifications, and policy updates. Our team provides implementation support and walkthrough sessions to ensure your teams can execute remediation efficiently.

06

Validation and Compliance Certification

After remediation, we conduct validation testing to confirm all controls meet regulatory requirements. You receive a formal compliance assessment report documenting your posture against both GDPR and DPDP Act, a compliance readiness certificate, and a roadmap for maintaining ongoing compliance as regulations evolve.

"We swap auditors every two years as policy. Security Brigade is the only firm we've kept continuously since 2016. The difference is Lemon — every engagement follows the same methodology, every finding gets three-layer review, and our RBI auditors have never questioned a report. That kind of consistency across 300+ annual assessments is rare."
CISO, Top-3 Indian Bank
Chief Information Security Officer

Read more client stories →

The Platform

Powered by Lemon

Most firms rely on individual tester skill. We built a platform that makes quality structural — informed by 6,700+ previous assessments.

lemon.securitybrigade.com/project/PRJ-2847
D
C
F
R
T
PROJECT PRJ-2847
Coverage Validation — acmecorp.com
94% covered
Endpoints
247 / 263
Parameters
1,847
Auth Flows
12 / 12
JS Routes
38 / 41
AI flagged 3 undiscovered endpoints
/api/v2/admin/export, /api/v2/billing/webhook, /internal/healthcheck
L1 Complete
L2 In Review
L3 Pending

Automated Data Flow Discovery

Lemon's fingerprinting capabilities identify personal data stores, processing endpoints, and cross-border transfer paths across your application and infrastructure stack automatically.

Structured Compliance Testing Workflows

Testing tasks for GDPR and DPDP Act requirements are pre-defined and assigned systematically, ensuring no regulatory requirement is missed regardless of which auditors are assigned.

Real-Time Client Dashboard

Your team gets live visibility into assessment progress, findings as they are identified, remediation status, and blockers — across all stakeholders including compliance, security, and development teams.

Compliance-Ready

Audit-ready reporting for every framework

As a CERT-In empanelled firm, our reports are accepted by Indian regulators and meet global framework requirements.

Data Protection Impact Assessment (GDPR Art. 35 / DPDP Significant Data Fiduciary)
Privacy Impact Assessments conducted thr
Security of Processing (GDPR Art. 32 / DPDP Reasonable Security Safeguards)
Web, API, mobile, network, and cloud pen
Data Minimization and Storage Limitation (GDPR Art. 5 / DPDP Sec. 8)
Technical assessment of data collection,
Cross-Border Data Transfer Safeguards (GDPR Art. 44-49 / DPDP Sec. 16)
Data flow mapping and technical validati
Consent Management and Data Subject Rights (GDPR Art. 6-7, 15-22 / DPDP Sec. 5-6)
End-to-end testing of consent collection
Automated Decision-Making and AI Compliance (GDPR Art. 22 / DPDP Provisions)
Assessment of AI systems making automate
Breach Detection and Notification Readiness (GDPR Art. 33-34 / DPDP Sec. 8)
Evaluation of incident detection capabil
Third-Party and Processor Risk Management (GDPR Art. 28 / DPDP Sec. 8)
Assessment of data processor agreements,

Industries

700+ clients across verticals

Every type of application architecture and business logic pattern — tested.

BFSIICICI Bank, HDFC, Yes Bank, UTI MF, Edelweiss
Fintech & PaymentsPhonePe, Amazon Pay, Groww, BillDesk
ManufacturingMahindra, Asian Paints, L&T, Hindalco
Retail & ConsumerSwiggy, Sephora, Pernod Ricard, Jubilant
Aviation & LogisticsEtihad Airways, DHL Express, Shadowfax
HealthcareCloudNine, Pharmeasy, Wave Health

Quality Assurance

Multi-Layer Expert Review for Compliance Accuracy

Every compliance finding undergoes three levels of validation before reaching your team.

Compliance assessment quality directly impacts business decisions and regulatory outcomes. A missed gap can lead to penalties, while a false finding wastes remediation resources. Security Brigade's structured L1/L2/L3 review process ensures every compliance finding is thoroughly validated, every gap is accurately assessed, and every recommendation is actionable and proportionate to the actual risk.

L1: Compliance Auditor Assessment

L1 auditors perform the detailed assessment — mapping data flows, testing technical controls, documenting gaps against GDPR and DPDP Act requirements, and producing proof-of-evidence for every finding.

L2: Senior Consultant Review

L2 senior consultants review assessment coverage, validate that all regulatory requirements have been evaluated, identify gaps in testing methodology, and ensure the compliance mapping is complete and accurate.

L3: Security Architect Validation

L3 security architects perform final validation — confirming impact assessments, verifying remediation recommendations are practical and proportionate, and ensuring the compliance report meets the quality standards required for regulatory and board-level consumption.

Deliverables

What you get

Reports for two audiences — executives who need the risk picture, and developers who need to fix the issues. With code-level guidance, not vague advice.

Comprehensive Gap Analysis Report

Detailed mapping of your current posture against every applicable GDPR article and DPDP Act provision, with severity ratings and specific evidence for each finding.

Data Flow and Processing Map

Visual documentation of all personal data flows across your systems, applications, cloud infrastructure, and third-party integrations, including cross-border transfer paths.

Technical Security Assessment Report

Detailed findings from penetration testing of privacy controls, with step-by-step proof-of-concepts, technology-specific remediation code examples, and CVSS severity ratings.

Prioritized Remediation Roadmap

Risk-prioritized action plan with specific technical fixes, policy updates, and process changes needed to close compliance gaps, organized by regulatory criticality and implementation complexity.

Executive Summary and Board Deck

Non-technical overview of compliance posture, key risks, and remediation progress designed for board-level and leadership team consumption.

Compliance Readiness Certificate

Formal certificate confirming your organization has undergone structured GDPR and DPDP Act compliance assessment and met the validated requirements, issued after successful remediation.

AI System Compliance Report

For organizations using automated decision-making, a dedicated assessment of AI system compliance covering transparency, explainability, and safeguard adequacy.

Ongoing Compliance Support

Post-engagement support including retesting of remediated controls, regulatory update advisories, and assistance during Data Protection Board inquiries or GDPR supervisory authority audits.

FAQ

Common questions

Can't find what you're looking for? Talk to our team.

Contact us
What is the difference between GDPR and the DPDP Act 2023?+
GDPR is the European Union's data protection regulation governing personal data of EU residents, while the DPDP Act 2023 is India's equivalent law governing digital personal data of Indian citizens. While both share core principles like purpose limitation, data minimization, and consent-based processing, the DPDP Act has India-specific provisions including Significant Data Fiduciary obligations, specific penalty structures up to Rs 250 crore, and provisions for government data access. Organizations with India-EU operations need dual compliance.
Who qualifies as a Significant Data Fiduciary under the DPDP Act?+
A Significant Data Fiduciary is designated by the Indian government based on factors including the volume and sensitivity of personal data processed, risk to data principals, potential impact on sovereignty and national security, and other prescribed criteria. Significant Data Fiduciaries face additional obligations including mandatory Data Protection Impact Assessments, appointment of a Data Protection Officer based in India, and periodic independent compliance audits. The government is expected to issue specific thresholds and criteria through rules under the Act.
How long does GDPR and DPDP Act compliance take?+
A typical dual compliance assessment takes six to eight weeks, covering data flow mapping, gap analysis, technical control testing, and report delivery. The total timeline to achieve full compliance depends on the number and complexity of gaps identified during assessment, your organization's remediation capacity, and the maturity of existing privacy controls. Organizations with established security programs and some privacy controls can often achieve compliance readiness within three to four months including remediation.
Does the DPDP Act apply to companies outside India?+
Yes. The DPDP Act applies to organizations outside India if they process digital personal data of individuals in India in connection with offering goods or services to data principals in India. This means global SaaS companies, e-commerce platforms, and service providers with Indian customers must comply. The extraterritorial reach mirrors GDPR's approach, though enforcement mechanisms and cross-border cooperation frameworks are still being established.
What penalties does the DPDP Act impose for non-compliance?+
The DPDP Act prescribes penalties up to Rs 250 crore per instance for the most severe violations, including failure to implement reasonable security safeguards to prevent data breaches and violations involving children's data. Other offenses carry penalties up to Rs 200 crore or Rs 150 crore depending on the specific provision violated. The Data Protection Board of India will adjudicate complaints and impose penalties. These figures are per violation, meaning cumulative penalties across multiple breaches could be substantially higher.
How is Security Brigade's approach different from policy-only compliance consultants?+
Most compliance consultants focus on policy documentation, privacy notices, and procedural checklists. Security Brigade takes a fundamentally technical approach — we map data flows from actual code and infrastructure, penetration test privacy controls to verify they work against real attacks, validate consent and deletion mechanisms end-to-end, and assess AI systems for automated decision-making compliance. Our assessments are driven by the Lemon audit management platform with L1/L2/L3 expert review, ensuring consistency and depth that document-based approaches cannot achieve.
Can Security Brigade help with India-to-EU cross-border data transfer compliance?+
Yes. Cross-border data transfer compliance is a core focus of our dual GDPR and DPDP Act assessments. We map all data flows between Indian and EU systems, evaluate transfer mechanisms including Standard Contractual Clauses and adequacy determinations, test encryption and security controls on data in transit, and ensure your transfer architecture satisfies requirements under both GDPR Articles 44-49 and DPDP Act Section 16. This is especially critical for IT services companies, SaaS platforms, and organizations with shared service centers across India and Europe.
What about compliance for AI systems and automated decision-making?+
Both GDPR Article 22 and DPDP Act provisions impose obligations on organizations using automated decision-making that significantly affects individuals. Security Brigade assesses AI system compliance covering transparency and explainability of automated decisions, human oversight and intervention mechanisms, data minimization in training datasets, bias evaluation, and documentation of impact on data subjects. We also support ISO 42001 AI Management System readiness for organizations seeking structured AI governance.
Do we need both GDPR and DPDP Act compliance or just one?+
If your organization processes personal data of both Indian and EU residents, you need compliance with both regulations. However, there is significant overlap in requirements — both mandate lawful processing, data minimization, security safeguards, breach notification, and data subject rights. Security Brigade's dual compliance methodology assesses both frameworks simultaneously, identifying where requirements align and where additional controls are needed for one framework versus the other. This approach is significantly more efficient than running two separate compliance programs.
How does Security Brigade ensure compliance assessment quality?+
Every compliance assessment undergoes Security Brigade's three-level review process. L1 auditors perform the detailed assessment and document findings with evidence. L2 senior consultants validate coverage, methodology, and accuracy of compliance mapping. L3 security architects perform final validation and ensure the report meets regulatory and board-level quality standards. This process is managed through our Lemon platform, which enforces structured workflows, artifact collection, and milestone tracking for complete traceability.

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