AMLEGALS
Compliance Calendar — 12 Months

DPDPA Annual Compliance Calendar

DPDPA compliance is not a one-time project — it is a continuous cycle of review, assessment, audit, and improvement. This month-by-month calendar maps every recurring obligation for Data Fiduciaries and Significant Data Fiduciaries.

12 Months48 TasksDF + SDFBoard ReportingAudit Cycle

Most organisations treat DPDPA as a one-time compliance exercise. The statute requires ongoing obligations — periodic audits (Rule 13), continuous grievance redressal (Section 13, Rule 8), breach readiness (Section 8(6)), and Board reporting for SDFs. This calendar transforms those obligations into a structured annual programme.

Foundation Review & Policy Reset

Q1 — January to March

January

Annual privacy policy review and update

Section 5, Section 6All Data Fiduciaries

DPO annual workplan submission to management

Section 10(2)SDF only

Consent notice review — verify all notices reflect current processing purposes

Section 5, Rule 3All Data Fiduciaries

Data processing register update — catalogue all processing activities

Section 8All Data Fiduciaries

February

Processor contract audit — review all data processing agreements for DPDPA compliance

Section 8(2), Rule 6All Data Fiduciaries

Cross-border transfer mapping update

Section 16All Data Fiduciaries

Children's data processing review — age verification mechanism assessment

Section 9, Rules 10-12All Data Fiduciaries

Grievance redressal mechanism testing

Section 13, Rule 8All Data Fiduciaries

March

Q1 Board compliance report preparation and presentation

Section 10SDF (recommended for all)

Data retention schedule review — identify data past retention period for erasure

Section 8(7), Section 12All Data Fiduciaries

Employee awareness training — annual refresher

Section 8(4)All Data Fiduciaries

Consent Manager integration check (if applicable)

Section 6(4), Rule 4All Data Fiduciaries
Assessment & Training Cycle

Q2 — April to June

April

DPIA execution for new or changed processing activities

Section 10, Rule 14SDF (recommended for all)

Algorithmic assessment for automated decision-making systems

Rule 14SDF only

Vendor security assessment cycle — evaluate processor safeguards

Section 8(2)All Data Fiduciaries

Privacy notice translation and accessibility review

Section 5All Data Fiduciaries

May

Breach response simulation drill — test incident response plan

Section 8(6), Rule 7All Data Fiduciaries

CERT-In reporting workflow test — verify 6-hour clock compliance

CERT-In Direction 2022All Data Fiduciaries

Role-specific training for IT, HR, marketing, and customer service teams

Section 8(4)All Data Fiduciaries

Data subject access request (DSAR) response time audit

Section 11-13All Data Fiduciaries

June

Q2 Board compliance report preparation and presentation

Section 10SDF (recommended for all)

Mid-year consent metrics review — consent rates, withdrawal patterns, purpose coverage

Section 6All Data Fiduciaries

Technology stack privacy review — new tools, SaaS, and cloud services assessment

Section 8All Data Fiduciaries

Regulatory update integration — incorporate new Board guidance or rule amendments

DPDPA/RulesAll Data Fiduciaries
Internal Audit & Vendor Review

Q3 — July to September

July

Internal compliance audit — comprehensive assessment against DPDPA requirements

Section 10, Rule 13SDF (recommended for all)

Audit evidence compilation — consent records, processing logs, security measures

Section 8All Data Fiduciaries

Privacy impact assessment for upcoming product/feature launches

Rule 14SDF (recommended for all)

DPO mid-year report to Board on compliance status

Section 10(2)SDF only

August

Vendor and processor audit cycle — on-site or remote assessment of key processors

Section 8(2), Rule 6All Data Fiduciaries

Data purging execution — delete data past retention period

Section 8(7)All Data Fiduciaries

Security safeguard review — encryption, access controls, anonymisation effectiveness

Section 8(4)All Data Fiduciaries

Cross-border transfer agreement renewals and updates

Section 16All Data Fiduciaries

September

Q3 Board compliance report preparation and presentation

Section 10SDF (recommended for all)

Annual audit report draft review

Rule 13SDF only

Grievance redressal effectiveness review — resolution times, escalation patterns

Section 13, Rule 8All Data Fiduciaries

Consent withdrawal processing audit — verify cascade to all processors

Section 6(6)All Data Fiduciaries
Year-End Closure & Forward Planning

Q4 — October to December

October

Annual audit completion and report finalisation

Rule 13SDF only

Year-end data inventory — comprehensive personal data mapping

Section 8All Data Fiduciaries

Board-level annual compliance presentation preparation

Section 10SDF (recommended for all)

Regulatory change impact assessment for coming year

DPDPA/RulesAll Data Fiduciaries

November

Next-year compliance roadmap and budget preparation

Section 10SDF (recommended for all)

Breach response plan annual update

Section 8(6), Rule 7All Data Fiduciaries

Training programme planning for next year — content update, scheduling

Section 8(4)All Data Fiduciaries

DPO annual performance review and resource assessment

Section 10(2)SDF only

December

Q4 and Annual Board compliance report and presentation

Section 10SDF (recommended for all)

Evidence archive — compile and secure all compliance documentation for the year

Section 8All Data Fiduciaries

Processor contract renewal cycle — negotiate updated DPDPA-compliant terms

Section 8(2), Rule 6All Data Fiduciaries

Year-end policy sign-off by management

Section 8All Data Fiduciaries

Compliance Calendar Advisory

Compliance is a continuous cycle, not a one-time project. AMLEGALS brings 27 years of regulatory experience to building annual compliance programmes that survive Board scrutiny and enforcement action.

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Insights & Answers

What practitioners and boards are asking

What is a DPDPA compliance calendar?

A DPDPA compliance calendar is a structured annual schedule of recurring obligations for Data Fiduciaries and Significant Data Fiduciaries. This includes quarterly Board compliance reports, periodic consent reviews, DPIA assessments (Rule 14), breach simulation drills (Section 8(6)), vendor audits (Section 8(2)), DPO reporting cycles, data retention reviews, employee training, and annual audits (Rule 13). DPDPA compliance is not a one time project. it requires a continuous cycle of review, assessment, audit, and improvement. AMLEGALS builds annual compliance programmes for organisations across all sectors.