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Every clause your vendor's DPA needs before DPDPA enforcement

Isha Verma

Isha Verma

Product LeadApril 11, 20266 min read

A hand signing a printed contract with a pen

A Data Processing Agreement that was fine under a generic privacy policy isn't automatically fine under DPDPA. The obligations a Data Fiduciary carries flow through to every processor touching that data, so the agreement needs to say so explicitly.

What to check before signing

  • Purpose limitation — the processor can't use data for anything beyond the stated engagement
  • Sub-processor disclosure and approval rights, not a blanket 'may engage subcontractors' clause
  • Breach notification terms that give you enough runway to still hit your own 72-hour window
  • Data return or deletion obligations at contract end, with a verifiable method, not just a promise

None of this is exotic — it's the same due diligence GDPR-era Data Processing Agreements already required. The difference is that under DPDPA, you need to be able to produce the signed agreement, not just point to a clause you believe exists.

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