DPDP Compliance for CA & Accounting Firms
CA and accounting firms handle highly sensitive financial data—PANs, bank details, income statements. Start your compliance journey.
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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 DPDP Compliance for CA & Accounting Firms, 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.
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Handling Government Identifiers
Accounting firms process PAN, Aadhaar, and bank account details for every client. Unlike retail businesses, your data sets include tax returns and payroll files containing employee salary structures. This information is personal data under Indian law because it identifies individuals through government-linked numbers. You must track exactly where these digital copies sit on your office servers and local computers.
The Statutory Retention Conflict
Income Tax and Companies Act rules require you to keep records for eight years or longer. However, DPDP requires you to delete personal data once the specific purpose is finished. You must document which specific section of the Income Tax Act overrides the DPDP deletion requirement for every file you store. This documentation justifies holding client data after a filing is complete.
External Processing Risk
Many firms use freelance accountants or cloud-based tax software to manage ledgers. You are responsible for how these external parties handle your clients’ PAN and Aadhaar data. Your engagement letters must now explicitly restrict these freelancers from using client data for any purpose other than the assigned audit or filing.
| Workflow | Personal Data Involved | DPDP Compliance Risk |
|---|---|---|
| Individual Tax Filing | PAN, Aadhaar, Bank Statements | Keeping Aadhaar copies after the filing is complete |
| Payroll Processing | Employee names, UAN, Salary details | Sharing salary sheets through unencrypted email chains |
| Audit Documentation | Director KYC, Bank sign-offs | Storing physical KYC copies in unsecured office cabinets |
| MCA Filings | Passport numbers, DIN details | Receiving sensitive ID proofs via personal WhatsApp accounts |
This week
Review your “Income Tax” folder. Identify one client who left your firm over two years ago. Check if you still have their Aadhaar or PAN card scan on your local drive. Delete these files unless a specific legal statute requires you to keep that exact digital copy.
Now think about your work. Where does personal data enter your workflows? Where does it sit? Who else touches it?
Frequently asked questions
Can I keep scans of client Aadhaar cards for "future reference"?
No. Once the specific filing or KYC process is finished, you must delete the scan unless a law like the PMLA requires retention. Keeping "just in case" files violates the purpose limitation rule.
Does DPDP apply to the financial data of a Private Limited company?
DPDP applies to the personal data of individuals, not corporate entities. However, it covers the PAN, Aadhaar, and addresses of the company's directors and employees processed during your engagement.
How do I handle data shared by clients over WhatsApp?
You must move these documents to a secure firm environment and delete the media from the chat history. Relying on WhatsApp for long-term storage of PAN or bank details creates a data leak risk you cannot control.