DPDPA Compliance Roadmap for SMEs
90-Day Implementation Plan for Small Businesses
"SME compliance is not about perfection—it is about demonstrable, proportionate effort aligned with business scale."
Small and medium enterprises face unique DPDPA compliance challenges: limited budgets, lean teams, and competing business priorities. This 90-day roadmap provides a structured approach to achieving proportionate compliance without overwhelming your organization.
1Days 1-30: Foundation
Establish the baseline privacy infrastructure required for any compliant organization.
- Week 1: Appoint privacy lead (can be existing role with added responsibility)
- Week 2: Conduct basic data inventory—what data, where stored, why collected
- Week 3: Draft/update privacy policy aligned with Section 5 requirements
- Week 4: Implement consent mechanism for customer-facing touchpoints
2Days 31-60: Operationalization
Build the operational processes that sustain ongoing compliance.
- Week 5: Establish grievance redressal mechanism (email + tracking)
- Week 6: Review and update third-party contracts with DPA clauses
- Week 7: Implement data retention schedule and deletion protocols
- Week 8: Conduct employee privacy awareness training
3Days 61-90: Hardening
Strengthen controls and prepare for regulatory scrutiny.
- Week 9: Security safeguards review (encryption, access controls)
- Week 10: Breach response protocol documentation
- Week 11: Internal audit of implemented controls
- Week 12: Management sign-off and compliance attestation
SME Reality Check: Not every control needs to be enterprise-grade. Regulators assess proportionality—controls appropriate to your scale and risk profile.
Key Takeaways
90 days is sufficient for foundational SME compliance
Proportionality is key—controls should match business scale
Privacy lead appointment is mandatory, full-time DPO is not (for non-SDFs)
Employee training is often the highest-ROI compliance investment
Documentation of efforts matters as much as perfect implementation
Statutory References
Download 90-Day SME Compliance Checklist
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