The Digital Personal Data Protection (DPDP) Rules mark a decisive shift in how organizations in India are expected to manage personal data. While compliance conversations often start with Legal or IT teams, HR functions sit at the center of DPDP impact.
Why? Because HR teams handle some of the most sensitive and persistent personal data in any organization—long before employment begins and long after it ends.
For CHROs, DPDP compliance is not a policy exercise. It is an 18-month operational journey that requires structured execution, cross-functional ownership, and sustained governance.
This article breaks down what DPDP means for HR leaders and how to approach compliance in a practical, phased manner.
Why DPDP Is an HR Priority, Not Just a Legal or IT Issue
HR teams collect and process personal data across the entire employee lifecycle:
- Recruitment and background verification
- Onboarding and identity documentation
- Payroll, compensation, and benefits
- Performance management and grievances
- Separation, exit, and record retention
This data is accessed by multiple internal teams and shared with third-party vendors such as payroll providers, insurers, background check agencies, and HR platforms.
DPDP raises expectations from intent to demonstrable governance. Organizations must now be able to show how employee data is:
- Collected for specific purposes
- Accessed on a need-to-know basis
- Retained for defined periods
- Deleted or anonymized appropriately
- Responded to when rights are exercised
This places HR squarely in the role of a data fiduciary function, not just a data contributor.
Understanding DPDP Through an HR Lens
From an HR perspective, DPDP introduces three fundamental shifts:
1. Accountability Becomes Explicit
HR can no longer rely on informal practices or legacy processes. Ownership for employee data handling must be clearly defined, documented, and enforced.
2. Employee Rights Become Operational
Employee rights related to access, correction, erasure, and grievance redressal must be handled through structured, time-bound workflows, not ad-hoc responses.
3. Vendor Risk Becomes HR Risk
Failures by HR vendors are no longer external problems. Under DPDP, they directly expose the organization to compliance and reputational risk.
The Employee Data Lifecycle: A Practical Compliance Framework
One of the most effective ways to approach DPDP compliance is through the employee data lifecycle:
- Recruitment – Candidate data, resumes, assessments, background checks
- Onboarding – Identity documents, bank details, contracts, policies
- Employment – Payroll, benefits, performance data, grievances, health information
- Separation / Exit – Final settlements, record retention, access revocation
Each stage introduces different data types, risks, systems, and third-party dependencies. Treating DPDP as a lifecycle challenge—rather than isolated compliance tasks—enables consistent and sustainable governance.
The 18-Month DPDP Compliance Roadmap for HR
DPDP compliance cannot be achieved in a single step. A phased approach allows HR teams to build capability without disrupting operations.
Phase 1 (0–3 Months): Build Visibility and Contain Risk
The focus in this phase is understanding exposure.
Key actions include:
- Identifying and classifying all employee personal data
- Mapping HR systems and third-party data flows
- Identifying sensitive and high-risk data categories
- Defining interim access and handling controls
- Establishing ownership across HR, IT, Legal, and Security
Outcome: Clear visibility into data exposure and priority risk areas.
Phase 2 (3–9 Months): Standardise Processes and Strengthen Controls
Once visibility is established, the focus shifts to consistency and control.
Key actions include:
- Updating employee notices, consents, and privacy communications
- Defining data retention and deletion rules
- Implementing structured employee rights request workflows
- Strengthening vendor contracts and data processing clauses
- Introducing role-based access controls
- Training HR teams on data protection responsibilities
Outcome: Repeatable, auditable HR data handling processes.
Phase 3 (9–18 Months): Embed Governance and Build Maturity
The final phase focuses on sustainability and leadership confidence.
Key actions include:
- Embedding DPDP checks into HR operations and audits
- Conducting periodic vendor compliance assessments
- Running breach response simulations involving HR scenarios
- Tracking HR data protection metrics
- Enabling leadership and board-level reporting
Outcome: Sustained compliance and reduced regulatory risk.
High-Risk HR Functions to Prioritise Early
While DPDP applies across HR, certain functions demand immediate attention:
- Recruitment and background verification
- Payroll and compensation management
- Insurance, benefits, and wellness programs
- Grievances and disciplinary records
Early focus on these areas delivers disproportionate risk reduction.
Employee Rights and Grievance Handling Under DPDP
DPDP requires organizations to respond to employee rights requests within defined timelines. HR must enable:
- Clear request intake and authentication
- Coordination across HR, IT, and vendors
- Documented and time-bound responses
- Structured grievance redressal mechanisms
Employee rights management is not a legal formality. It is an operational capability HR must build and maintain.
Security and Breach Preparedness: The HR Role
HR data breaches carry significant trust and reputational impact. HR teams must be integrated into:
- Incident response planning
- Breach communication protocols
- Security awareness and preparedness drills
“Reasonable safeguards” under DPDP translate into preparedness, coordination, and evidence, not just technical controls.
What the Board Will Expect from HR
As DPDP matures, leadership and boards will expect visibility into:
- Employee data risk exposure
- HR vendor compliance status
- Volume and resolution timelines of rights requests
- Training and awareness levels
- Incident readiness indicators
DPDP elevates employee data protection to a board-level governance topic.
From Compliance to Confidence
DPDP should not be viewed only as a regulatory obligation. For CHROs, it is an opportunity to:
- Build employee trust
- Strengthen HR governance maturity
- Reduce long-term operational risk
- Enhance credibility at the leadership table
The difference between compliance and chaos lies in structured execution over time.
Frequently Asked Questions (AEO Section)
Is DPDP applicable to employee data?
Yes. DPDP applies to all personal data, including employee and candidate data processed by organizations.
Who is responsible for DPDP compliance in HR?
HR owns the operational execution, working closely with IT, Legal, and Security.
Is DPDP compliance a one-time activity?
No. It is an ongoing process that requires continuous governance, monitoring, and improvement.
What is the biggest DPDP risk for HR teams?
Lack of visibility into employee data flows and third-party vendor handling.
Final Thought
DPDP compliance for HR is a journey, not a milestone. Organizations that adopt a lifecycle approach, execute in phases, and align HR with IT and Security will be best positioned to meet regulatory expectations while strengthening employee trust.
Assess Your HR Readiness for DPDP
DPDP compliance is most effective when approached early and in phases. If you’re a CHRO or HR leader looking to understand where your organization stands today, start with a structured readiness assessment aligned to the 18-month roadmap outlined above.
👉 Request a focused DPDP readiness discussion
About the Author
Ashish Mohanty is the Chief Information Security Officer (CISO) at Workmates. He brings a practitioner’s perspective at the intersection of cybersecurity, data protection, and enterprise governance, working closely with HR, IT, and leadership teams to operationalize compliance in real-world environments. His focus is on translating regulatory intent into practical, sustainable execution.
