90-Day DPDP Compliance Roadmap
A practical, actionable 90-day plan to take your organization from zero to DPDP-compliant. Book a DPDP clarity call.
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DPDP Action Sheet
Use this before your next workflow goes live. It keeps the useful parts visible and turns DPDP into checks your team can actually answer.
For 90-Day DPDP Compliance Roadmap, the DPDP question is how personal data enters the workflow, where it is stored, which tools touch it, what purpose was explained, and how deletion or withdrawal will work.
1. Lead Forms
Check:
- What data are you collecting?
- Is the purpose clear at the point of collection?
- Is marketing consent separate from service communication?
- Can the user withdraw consent later?
Common mistake: one checkbox that silently covers newsletters, sales calls, partner sharing and remarketing.
2. Email and WhatsApp
Check:
- Who is on the list?
- Where did consent come from?
- Is the list imported from a vendor, event, webinar, scrape or old CRM?
- Can you prove the source of consent?
Common mistake: treating every lead as permanently marketable.
3. Ads and Retargeting
Check:
- Are pixels or ad platforms receiving identifiable user behavior?
- Are audiences built from customer lists?
- Are lookalike or remarketing audiences using personal data?
Common mistake: assuming "the ad platform handles it" means your company has no DPDP responsibility.
4. Website Analytics
Check:
- Which tools run on the site?
- Are IP address, device identifiers, session IDs or form fields being captured?
- Is analytics used only for measurement, or also for profiling and targeting?
Common mistake: installing tools first and asking privacy questions later.
5. Vendor List
Make a quick list:
- CRM
- Email platform
- WhatsApp provider
- Analytics
- Ad pixels
- Form tool
- Landing page builder
- Webinar tool
For each vendor, answer: what data goes there, why, who can access it and how deletion works.
6. This Week's Action
Map one campaign from first click to final follow-up. Mark every place personal data is collected, enriched, shared, uploaded or used for targeting.
If your team cannot answer where the data came from and where it goes next, start with a data flow map before rewriting policy copy.
Book a DPDP clarity callWant all of this handled, end to end? Sanctum is the all-in-one DPDP compliance programme behind this site: legal position, data map, gap analysis, implementation, tooling, training, readiness opinion, and breach cover under one accountable owner. How all-in-one DPDP compliance works or see the Sanctum programme.
Prioritizing High-Risk Data Silos
A 90-day sprint requires identifying “dark data” hidden in local Excel sheets and old email attachments. Many Indian firms keep years of customer KYC documents on unencrypted office desktops or shared Google Drives. You must isolate these files and move them to a central, access-controlled environment within the first 30 days to prevent unauthorized internal access.
Updating Vendor Data Processing Agreements
Most businesses use third-party payroll or cloud storage providers. Within 90 days, you must sign specific DPDP-aligned addendums with these partners. This ensures they only process employee PAN and bank details for the exact purpose of salary disbursement and tax filing, rather than using that data for their own analytics.
| Workflow | Personal Data Involved | DPDP Risk |
|---|---|---|
| Employee Payroll | Bank account numbers, PAN | Data leaks through third-party payroll apps |
| Lead Generation | Phone numbers from social media | Contacting leads without verifiable consent records |
| Customer Support | Email addresses in helpdesk tickets | Storing PII indefinitely after ticket closure |
| KYC Verification | Aadhaar numbers, photographs | Storing raw images instead of masked copies |
The Legacy Consent Conflict
The biggest hurdle in a 90-day roadmap is the “Consent Gap.” You likely have thousands of phone numbers collected before the DPDP Act. During this window, you must decide which records have a clear, documented purpose and which must be deleted because you cannot prove how the data was originally collected.
This week
Open your CRM or primary customer database. Export a list of all data fields you collect, such as “Date of Birth” or “Alternate Number.” Delete any field that your business has not used for a specific business process in the last six months.
Now think about your work. Where does personal data enter your workflows? Where does it sit? Who else touches it?
Frequently asked questions
Can we use the 90-day window to send a mass email asking for new consent?
Yes, but the notice must be available in English and any of the 22 languages listed in the Constitution if the user prefers. You must record the exact timestamp and version of the notice the user accepted.
What happens to our physical paper records during this 90-day sprint?
Physical documents like visitor logbooks or printed CVs fall under the Act. You must move these to locked cabinets and create a simple logbook to track which employees access those files.
Do we need to appoint a Data Protection Officer (DPO) immediately?
Only if the government classifies you as a Significant Data Fiduciary based on data volume. For most firms, the 90-day goal is designating one staff member to respond to users who want to see or delete their data.