DPDPA Gap Assessment for Multinational Corporations
Mapping GDPR/CCPA Controls to Indian Requirements
"GDPR compliance is 70% of the way to DPDPA compliance. The remaining 30% is where MNCs stumble."
Multinational corporations with existing GDPR or CCPA programs have a head start on DPDPA compliance. However, India's law has unique requirements that existing controls may not satisfy. This guide identifies the critical gaps.
1GDPR to DPDPA Mapping
Many GDPR controls translate directly to DPDPA, but terminology and scope differ.
- GDPR Controller → DPDPA Data Fiduciary
- GDPR Processor → DPDPA Data Processor
- GDPR DPO → DPDPA DPO (SDF only)
- GDPR Consent → DPDPA Consent (stricter "unconditional" requirement)
- GDPR Legitimate Interest → No direct DPDPA equivalent
2Critical DPDPA-Specific Gaps
These requirements have no GDPR equivalent and require new controls.
- Section 5 notice in 22 Indian languages (Rule 3)
- Consent Manager interoperability (where used)
- No "legitimate interest" fallback—consent or Section 7 only
- Children defined as under 18 (vs. GDPR's 16)
- Significantly Data Fiduciary notification criteria differ
MNC Alert: The 22-language notice requirement catches most MNCs off guard. Budget for professional translation and consent platform updates.
Key Takeaways
GDPR compliance provides 70% foundation for DPDPA
Legitimate interest processing requires re-evaluation
22-language notice requirement is operationally significant
Children's data threshold is higher (18 vs. 16)
Existing DPO may satisfy DPDPA SDF requirement
Statutory References
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