PineBrook Logo IconPineBrook Technologies

What DPDPA asks of an organisation your size

Every organisation that handles digital personal data has the same core duties. Size changes how much work it takes, and the largest data holders carry extra duties.

What applies to mid-market teams

  • Clear notice and consent for each purpose
  • A way for people to exercise their rights
  • Reasonable security safeguards
  • Breach notice to the Board and affected people
  • Contracts that bind your processors

Where teams your size usually start

  1. First. Map your data

    You can't fix what you can't see.

  2. Then. Fix consent

    Notices and choices in your main journeys.

  3. Then. Review vendors

    Your processors carry your risk.

Significant Data Fiduciaries

The government can name organisations as Significant Data Fiduciaries based on the volume and sensitivity of data they handle. They must appoint a DPO and run independent audits and impact assessments.

Side by side

How the duties compare across organisation sizes
Startups and MSMEsMid-marketLarge enterprises
Typical first stepData map and noticesGap assessmentProgramme across business units
Who owns itA founder or ops leadCompliance or IT headDPO and privacy team
Where it gets hardTime and know-howMany tools, few ownersLegacy systems and scale
Extra dutiesPossible exemptions, if notifiedCore dutiesSDF duties, if designated

Questions

The Act lets the government exempt some classes of organisation, and it names startups as one it may consider. Check what is notified at the time, and assume the core duties apply until you confirm an exemption with your counsel.

The government names Significant Data Fiduciaries by notification, based on factors such as the volume and sensitivity of the data they handle. Check the notifications and ask your counsel. We can help you prepare either way.

With a map of the data you hold and a clear notice. Those are the first two steps most teams take.

Scoped to your size