Real citizensin test data.
The weakest environment holds the most complete copy.
In one line: It is not prohibited, but security safeguards apply to every environment. Masking or synthetic data reduces risk and is good practice.
Test data is not fake just because the server is.
The scene
The developers needed realistic data, so someone restored last month's production backup to the test server. It had weaker access controls, a public IP and two million beneficiaries' bank details.
Where the thinking breaks
Reasonable safeguards include non-production
Section 8(5) security duties apply wherever personal data sits, including development, test, staging and analytics.
Monday morning
- 01List every non-production environment.
- 02Check which contain real personal data.
- 03Mask or delete it.
Questions, answered plainly
Can production personal data be used in test environments under DPDPA?
It is not prohibited, but security safeguards apply to every environment. Masking or synthetic data reduces risk and is good practice.
What counts as reasonable security safeguards under DPDPA?
The Rules list measures including encryption, obfuscation or masking, access control, logging and monitoring, backups and contractual safeguards with processors.
Tell us where your data sits.We'll show you where the exposure is.
A partner replies within one working day, with a first view on your penalty exposure.
Speak to a partner