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Data Processing Agreement Drafting Masterclass

DPDPA-Compliant DPA Architecture

12 min read8 December 2024
"A well-drafted DPA allocates risk appropriately. A poorly drafted DPA creates unlimited liability exposure."

Data Processing Agreements are the contractual backbone of DPDPA compliance when engaging third-party processors. This masterclass covers essential clauses, negotiation strategies, and common drafting pitfalls.

1Essential DPA Clauses

These clauses are legally required or strongly advisable.

  • Subject matter and duration of processing
  • Nature and purpose of processing
  • Categories of personal data and Data Principals
  • Processor obligations (confidentiality, security, staff)
  • Sub-processor engagement and oversight
  • Breach notification timeline and content
  • Audit cooperation and inspection rights
  • Deletion/return of data upon termination

2Liability Allocation Strategies

Liability provisions are heavily negotiated. Know your position.

  • Mutual indemnification for own breaches (standard)
  • Processor indemnification for sub-processor breaches (advisable)
  • Liability caps: Fixed amount vs. contract value multiple
  • Carve-outs: Gross negligence, willful misconduct
  • Insurance requirements: Cyber liability minimums
Counsel Advisory

Negotiation Leverage: Processors accepting unlimited liability will price that risk into their fees. Reasonable caps benefit both parties.

Key Takeaways

1

DPAs are mandatory for all processor engagements

2

Essential clauses are non-negotiable compliance requirements

3

Liability allocation is the most contested DPA area

4

Sub-processor provisions prevent supply chain risk

5

Audit rights should be practical, not theoretical

Statutory References

Section 8(7) (Processor Engagement)Section 8(5) (Security)Section 8(6) (Breach Notification)Rule 7 (Breach Notification)

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