Step 11 - Compliance Checklists by Industry
Step 11: Compliance Checklists by Industry
While the Digital Personal Data Protection Act (DPDPA), 2023 applies to all organizations, the risks and requirements differ depending on the industry. Each sector handles unique categories of personal data — financial, health, identity, behavioral — and therefore needs tailored compliance steps.
1. Banking and Financial Services
Data Handled: KYC documents, account details, transaction histories, credit scores.
Checklist:
- Encrypt all sensitive data (Aadhaar, PAN, bank accounts).
- Retain KYC data only for the RBI-mandated period (10 years after account closure).
- Appoint a Grievance Officer; large banks will likely qualify as SDFs and must appoint a DPO.
- Test and document breach response plans to meet the 72-hour reporting deadline.
- Audit third-party vendors (credit bureaus, payment gateways) for DPDPA compliance.
Create a customer rights portal where account holders can request access, correction, or closure of their data.
2. Insurance
Data Handled: Health records, claims history, Aadhaar, nominee details.
Checklist:
- Limit collection of health records only to what is necessary for claims.
- Update privacy notices on claim portals and apps.
- Maintain secure, encrypted storage for medical reports.
- Create a mechanism to honor withdrawal of consent for marketing communications.
- Conduct DPIAs before deploying AI/ML claim approval systems.
Maintain a breach notification template ready for immediate dispatch to policyholders if sensitive health data is exposed.
3. Healthcare and Pharmaceuticals
Data Handled: Patient health records, diagnostic reports, genetic and biometric data, clinical trial data.
Checklist:
- Implement strict access controls (doctors only, need-to-know basis).
- Encrypt medical histories and diagnostic reports.
- Anonymise or pseudonymise data used for research and trials.
- Retain data only as long as medically or legally necessary.
- Train staff to recognize sensitive data breaches (e.g., accidental disclosures).
Use a Consent Manager platform when seeking permission from patients for sharing medical data in research projects.
4. E-Commerce and Retail
Data Handled: Names, delivery addresses, payment details, browsing and purchase histories.
Checklist:
- Collect only data needed to complete transactions and deliveries.
- Delete or anonymise customer addresses after return/warranty periods expire.
- Provide clear notices when collecting consent for marketing or loyalty programs.
- Secure payment data under PCI-DSS standards.
- Audit logistics partners handling delivery information.
Implement an “unsubscribe with one click” feature in promotional emails to simplify consent withdrawal.
5. Social Media and Tech Platforms
Data Handled: Photos, messages, posts, browsing activity, children’s data, behavioral data for ads.
Checklist:
- Obtain verifiable parental consent for users under 18.
- Provide simple tools for consent withdrawal and account deletion.
- Publish detailed privacy notices explaining use of algorithms for recommendations/ads.
- Conduct algorithm fairness reviews to avoid bias.
- Implement real-time breach monitoring.
Create an in-app privacy dashboard where users can view, download, or delete their data directly.
6. Stock Broking and Investment
Data Handled: PAN, Aadhaar, trading histories, income proofs, bank details.
Checklist:
- Retain financial data only as required by SEBI (usually 7 years).
- Encrypt and secure transaction records.
- Notify clients immediately in case of a breach.
- Limit sharing of trading data with third-party analytics providers.
- Conduct periodic third-party security audits.
Establish a dedicated helpline and email (e.g., privacy@broker.com) for investors to request corrections or lodge complaints about data handling.
7. Crypto Exchanges
Data Handled: KYC details, wallet addresses, trading activity, linked bank accounts.
Checklist:
- Conduct strict due diligence on third-party wallet and KYC providers.
- Disclose if user data is processed on foreign servers.
- Encrypt wallet keys and trading logs.
- Notify users and the Board within 72 hours of any breach.
- Maintain records of cross-border transfers for audit.
Use multi-factor authentication (MFA) as a mandatory safeguard for user accounts and store KYC data separately from trading logs.
Why Industry-Specific Checklists Matter
The same law applies differently depending on the type of data and risks involved. A hospital leaking genetic test results is far more damaging than a retailer losing a phone number. Tailored checklists help organizations focus on the highest-risk areas in their sector and implement compliance efficiently.