Skip to content
The 7-obligation schedule

DPDP Schedule I Technical Safeguards — Complete Checklist

Schedule I is the technical-controls schedule of DPDP Act 2023 — 7 obligations the Data Protection Board uses to assess breach culpability.

Failing the schedule increases the penalty band. Meeting it does not eliminate the breach, but caps the financial exposure.

7Schedule I obligations
May 2027enforcement date
₹250 Crmax penalty
Freefirst scan
7 Schedule I obligationsDPDP Act 2023 alignedFree first gap analysis

Obligation 1 — Appropriate technical and organisational measures

The first Schedule I obligation requires data fiduciaries to implement 'appropriate technical and organisational measures' commensurate with the volume, sensitivity, and risk profile of the personal data being processed. In practice: encryption at rest (database, file storage, backups), encryption in transit (TLS 1.2+), key management (rotation, HSM where applicable), secure software development lifecycle, and periodic code review. The threshold of 'appropriate' is risk-proportional — a payments fintech faces a higher bar than a brochureware website.

Obligation 2 — Reasonable security safeguards against breach

Operational controls to prevent unauthorised access: access control (least-privilege, MFA, periodic access review), network segmentation, endpoint protection, intrusion detection, vulnerability management (patching SLA, annual VAPT), backup integrity. This is the obligation most often tested against in post-breach analysis — what controls were in place, were they exercised, were they bypassed by reasonable adversary effort.

Obligation 3 — Breach response and notification

Capability to detect, contain, and respond to a personal data breach, and to notify the Data Protection Board within the prescribed time (currently 72 hours from awareness, per draft rules). Requires a documented incident response plan, defined breach severity bands, communication templates, and tested executive escalation paths.

Obligation 4 — Periodic audit and review

The schedule expects a regular cadence — typically annual — of independent technical review. VAPT is the primary evidence artifact: a third-party-attested vulnerability assessment showing the safeguards were tested and findings remediated. Bachao.AI runs annual VAPT scan cycles with Schedule I mapping built in; your hired auditor reviews the output and attests.

Obligation 5 — Retention limits

Personal data must be deleted once the original purpose is complete and no other lawful basis to retain exists. Requires data lifecycle tracking, automated retention policies in data stores, and verifiable deletion workflows. The schedule explicitly cites deletion failure as a breach-multiplier.

Obligation 6 — Vendor / processor risk management

Where personal data is processed by a third party (cloud provider, payment processor, analytics platform, support tooling), the data fiduciary must flow Schedule I obligations down via contract and verify compliance via vendor audits. The fiduciary remains liable even when the breach originates with the processor.

Obligation 7 — Logging and audit trail

Every personal-data-affecting event must produce a tamper-evident log entry: who accessed what data, when, from which network, for what stated purpose, with which authorisation. Logs must be retained for at least the regulator-specified period (currently a year per draft rules) and made available on Board request.

How Bachao.AI helps you meet Schedule I

Bachao.AI's VAPT + DPDP gap analysis is the technical-controls evidence pack for obligations 1, 2, 4, and 7. The deliverable: a CERT-In aligned VAPT report with Schedule I mapping per finding, a gap matrix showing which obligations need additional work, and a remediation roadmap prioritised by Board penalty exposure. For obligations 3, 5, and 6, we provide a compliance partner network introduction (DPDP-specialised CAs and consent management platforms).

Get your DPDP Schedule I baseline today

Free first VAPT scan with Schedule I mapping. See where you stand before May 2027 enforcement.

Find your vulnerabilitiesStart free scan →