Multi-Tenant Data Isolation Under DPDPA
Architectural Compliance for SaaS Platforms
"In multi-tenant architectures, one tenant's breach cannot be permitted to compromise another tenant's data."
Multi-tenant SaaS platforms present unique DPDPA compliance challenges. Data from multiple Data Fiduciaries coexists in shared infrastructure, creating complex liability scenarios. This guide addresses architectural patterns that satisfy regulatory requirements.
1The Multi-Tenancy Compliance Challenge
DPDPA does not contemplate multi-tenant architectures, but its principles must be applied.
- Each tenant is a separate Data Fiduciary with independent obligations
- You (SaaS provider) are a Data Processor for each tenant
- Tenant data must be logically isolated at minimum
- Breach in one tenant cannot expose another tenant's data
- Audit and deletion must be tenant-specific
2Isolation Architecture Options
Choose isolation levels appropriate to data sensitivity and customer requirements.
- Row-level isolation: Minimum viable, tenant ID on every row
- Schema-level isolation: Separate schemas per tenant in shared DB
- Database-level isolation: Dedicated database per tenant
- Infrastructure-level isolation: Dedicated compute/storage (enterprise tier)
Architecture Decision: Row-level isolation is acceptable for most use cases but requires rigorous access control testing. A single missing WHERE clause creates a breach.
3Breach Containment Protocols
When breaches occur, demonstrate that only affected tenant's data was exposed.
- Forensic logging must be tenant-attributed
- Access logs must prove isolation was maintained
- Notification must be tenant-specific, not platform-wide
- Remediation must be demonstrably contained
Key Takeaways
Multi-tenant SaaS must maintain logical data isolation
Isolation level should match data sensitivity
Breach notification is tenant-specific obligation
Audit trails must be tenant-attributed
Deletion requests require tenant-scoped execution
Statutory References
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