Data Protection

The DPDP Rules, Without Missing What Matters

How to read India's new data-protection framework as a compliance system—not a flat document—using structural AI.
Pranav RamakrishnanAdvocate & Legal Engineer

November 26, 2025

10 min read
Share
The DPDP Rules, Without Missing What Matters
EXECUTIVE SUMMARY
Inside this article: Full comparison table of Data Fiduciary vs Significant Data Fiduciary obligations. Consent lifecycle flowchart. Compliance matrix with timelines. Sample operational checklists.

The DPDP Act, 2023 and DPDP Rules, 2025 form a web of role-based duties, conditional obligations, and exceptions. This article breaks them into structured compliance tables—which obligations apply to which roles, which duties activate above thresholds, and how the consent lifecycle flows from notice to erasure. Scroll down for the comparison matrices.

Why DPDP Compliance Is Not Static

Digital regulation moves faster than most organisations can keep up with, and data-protection law moves fastest of all. Anyone familiar with GDPR knows that compliance is never static; obligations grow, definitions shift, and what counted as compliant last quarter may no longer be enough. This pattern is well documented, including in systematic reviews showing how GDPR obligations continually expand over time.

India has followed a similar trajectory. The DPDP Act, 2023 and the DPDP Rules, 2025 mark the end of an eight-year journey that began with the Puttaswamy judgment in 2017 and passed through multiple drafts and rewrites, with more than two years between the Act's passage and the operational Rules. The challenge is not just reading the Rules. It is understanding their structure as they evolve.

India's Data Protection Journey: 2017 → 2025

Puttaswamy (2017)

Constitutional Right to Privacy

DPDP Act (2023)

Primary Legislation

DPDP Rules (2025)

Operational Framework

Eight years from constitutional recognition to operational rules—compliance is never static.

Suit by jhana

Built for exactly this. It does not just summarise regulatory text; it breaks it into obligations, dependencies, roles, flows, and checklists so users can extract real value without missing what matters.

Data Fiduciary vs Significant Data Fiduciary: Full Comparison

The DPDP Rules are not a simple regulatory document. They are a web of role-based duties, conditional obligations, and exceptions that change meaning depending on how the pieces connect. A lawyer or compliance team does not just "read" the Rules. They have to reconstruct them.

The Reconstruction Challenge

That means mapping which obligations apply to Data Fiduciaries versus Significant Data Fiduciaries, which duties activate only above certain thresholds, which exceptions override which clauses, and how definitions shift the scope of an obligation.

Even a quick look at the Rules shows this: consent mechanics are split across multiple clauses, security safeguards sit separately, and breach-reporting loops depend on specific triggers. Meaning emerges only when these parts are held together as a system, not in isolation.

Data Fiduciary

Any entity determining purpose & means

Obtain valid consent before processing

Provide itemised notice to Data Principals

Implement reasonable security safeguards

Report breaches to Board & affected persons

Erase data upon withdrawal or purpose completion

Respond to Data Principal requests

Significant Data Fiduciary

Notified based on volume, sensitivity, risk

All Data Fiduciary obligations, plus:

Appoint a Data Protection Officer (DPO)

Conduct periodic Data Protection Impact Assessments

Appoint an independent Data Auditor

Submit annual compliance reports

Enhanced breach notification timelines

How Suit Reconstructs the Framework

This is exactly the kind of complexity Suit is built to handle. Instead of flattening the Rules into a summary, Suit reads them structurally. It detects each defined role, identifies every obligation tied to that role, traces dependencies across clauses, and assembles the hidden flows that sit underneath the text.

How Suit Reconstructs the DPDP Framework
LayerWhat Suit ExtractsValue to User
RolesData Fiduciary, Significant Data Fiduciary, Data Processor, Data PrincipalKnow exactly which obligations apply to your entity
ObligationsConsent, notice, security, breach reporting, erasure, response timelinesComplete checklist without missing conditional triggers
ThresholdsVolume, sensitivity, risk factors for SDF classificationUnderstand when enhanced duties activate
FlowsConsent lifecycle, breach notification sequence, erasure workflowSee procedures as connected sequences, not isolated clauses
ExceptionsLegitimate uses, state exemptions, processing without consentKnow when obligations are modified or overridden
Suit turns the Rules into a map—not a flat summary.

Suit turns the Rules into a map: what applies to a Data Fiduciary, what applies only to a Significant Data Fiduciary, what duties activate only when a condition is triggered, and which exceptions restrict or override an obligation. By breaking the Rules into obligations, thresholds, roles, and flows, Suit lets users see the framework the way regulators intended it, not purely as obligations or rules but as a compliance system.

Consent Lifecycle Under DPDP
1

Notice

Itemised, clear, accessible

2

Consent

Free, specific, informed

3

Processing

Purpose-bound, minimal

4

Withdrawal

Easy as giving consent

5

Erasure

Complete, verifiable

Once Suit reconstructs the DPDP framework, users can immediately begin working with it. They can extract a clean checklist of obligations for Data Fiduciaries or Significant Data Fiduciaries, generate a flow of the consent lifecycle, review breach-reporting requirements as a structured sequence, or map retention and erasure rules without missing conditional triggers.

What Users Can Extract Immediately

Clean checklist of obligations for Data Fiduciaries or SDFs

Flow of the consent lifecycle from notice to erasure

Breach-reporting requirements as a structured sequence

Retention and erasure rules with conditional triggers

Comparative analysis: DF vs. SDF duties

Timeline table: response periods, notification deadlines, retention windows

Because Suit holds the entire Rules document together as one structure, users do not have to worry about losing context or skipping a dependency. The value is not in producing a summary. It is in giving lawyers and compliance teams a clear, reliable picture of what the law actually requires.

Compliance Matrix: Obligations, Timelines & Operational Steps

One of the clearest examples of this is how users run full compliance-mapping exercises through Suit. A regulatory team can input a structured prompt asking Suit to generate a DPDPA compliance matrix built directly from the Act and the Rules.

Sample Compliance Matrix Output
EntityObligationRule/SectionTimelineOperational Step
Data FiduciaryObtain valid consentRule 3, S.6Before processingImplement consent mechanism with itemised purposes
Data FiduciaryProvide noticeRule 4, S.5At/before collectionDisplay privacy notice in accessible format
Data FiduciaryBreach notificationRule 7, S.872 hours to BoardEstablish incident response protocol
SDFAppoint DPORule 10Upon notificationDesignate qualified officer, publish contact
SDFDPIARule 11PeriodicConduct assessment, document findings
SDFData AuditorRule 12AnnualEngage independent auditor, submit report
Suit identifies obligations for each regulated entity, ties every requirement to the exact Rule or Section, and converts them into practical operational steps.

Suit then identifies obligations for each regulated entity, ties every requirement to the exact Rule or Section, and converts them into practical operational steps. It produces a consolidated timeline table covering response periods, notification deadlines, retention windows, and other statutory time limits. It can also generate a short comparative analysis between Data Fiduciaries and Significant Data Fiduciaries or between controller-level and processor-level duties.

Instead of a flat summary, users receive a structured and complete view of the entire compliance landscape, built strictly from the text.

Staying Current as the Law Evolves

The DPDP Act and the DPDP Rules will continue to evolve, and compliance will only get more complex from here. Suit gives lawyers, founders, and compliance teams a way to keep pace without losing structure. It turns regulation into something legible, traceable, and complete, so users can work with confidence instead of guesswork.

The Easter Egg

And for those who look closely, there is an easter egg built into Suit: you can attach your session to jhana's AI paralegal, a system that understands the full context of your file and the work you are doing. You can speak to it the way a real team would.

The DPDPA Act was enacted in 2023 and the Rules were notified in 2025. Study the Act, the Rules, relevant commentary, textbook jurisprudence, and US or GDPR jurisprudence, along with related Indian caselaw. Then prepare a guidance memo for founders, engineers, and product teams, mapping obligations, definitions, and deviations.

, Sample Paralegal Prompt

This is where the system reveals its full value. It does not just explain the law. It works with it. As the DPDP framework grows, Suit keeps the structure intact, the meaning stable, and the compliance picture complete.

KEY TAKEAWAY

The DPDP Rules are not a document to be read—they are a system to be reconstructed. Suit by jhana does exactly that: breaking regulation into obligations, roles, thresholds, and flows so compliance teams see the framework the way regulators intended. As the law evolves, Suit keeps the structure intact and the compliance picture complete.

Contents

Topics

DPDP Act 2023DPDP Rules 2025Data FiduciarySignificant Data FiduciaryDPDP compliance checklistconsent managementbreach notification DPDPDPDP vs GDPRIndia data protectionPuttaswamy judgmentDPO appointmentDPIA requirementsdata protection auditLegal AIjhana Suitcompliance mappingdpdpadpdprdpdp rules

Try jhana for your practice

Document intelligence for legal teams. Start with 50 free pages.

Join FreeBook Demo

Continue Reading

Gemini vs. Perplexity vs. ChatGPT vs. a Donkey: the "2026 best legal AI" is all of them

Strategic Vision
15 min

Section 149 Reassessment Limitation: Automated Analysis with Page-Linked Citations

Tax & Compliance
14 min

Portfolio Review Automation: SEBI PM Compliance + AML/CFT + DPDP Matrix

Wealth Advisory
12 min

Discussion

Comments • Share your thoughts and questions below