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Affected individuals without delay, and the Data Protection Board within 72 hours. Under the DPDP Rules, 2025 a Data Fiduciary must tell affected Data Principals in plain language through their registered mode of communication, send the Board an initial intimation promptly, and file a detailed report within 72 hours covering nature, extent, data involved, timeline, remedial measures and findings. Failure to notify carries a penalty of up to ₹200 crore.
Most organizations discover the true state of their security program in the worst possible way: mid-incident, with a clock running. The Digital Personal Data Protection Act, 2023 makes that clock explicit — and short.
The Act defines a personal data breach broadly: any unauthorized processing of personal data, or accidental disclosure, acquisition, sharing, use, alteration, destruction, or loss of access that compromises its confidentiality, integrity, or availability. Note what is missing: a materiality threshold. A misdirected export, a misconfigured bucket, a lost laptop with unencrypted records — each can qualify, whether or not an attacker was involved.
Under the DPDP Rules, 2025, when a breach occurs a Data Fiduciary owes two distinct notifications:
Failure to notify carries its own penalty under the Act's Schedule — up to ₹200 crore — separate from the up-to-₹250-crore exposure for failing to maintain reasonable security safeguards in the first place. A breach can therefore generate two independent penalty events: one for the safeguard failure, one for the notification failure.
Seventy-two hours sounds like three days. In practice it decomposes into a brutal sequence: detect the incident, confirm personal data is involved, scope which records and which people, classify severity, draft principal-facing notices your lawyers will sign, dispatch them across channels, file the initial intimation, then assemble a detailed, accurate report for the Board — while simultaneously containing the incident itself.
Organizations that meet the window share three traits: they maintain a live map of where personal data lives (so scoping takes hours, not days); they keep pre-approved notification templates in every language they serve; and they rehearse. Organizations that miss it usually lost the first 48 hours deciding who owns the problem.
A DPDPA-ready breach response program looks like this:
Run a tabletop exercise against the 72-hour window twice a year. Time each stage. Most teams discover their true bottleneck is not detection but drafting and approval — exactly the stages that can be prepared in advance.
Data Adhikaar by Qodequay Technologies builds this playbook into software. The Suraksha agent drives the 72-hour window end to end: classifies the incident, scopes affected Data Principals from the live data map, drafts principal and Board notifications for human approval, dispatches them, and time-stamps every step into a tamper-evident Evidence Vault — so when the Board asks what you did and when, the answer is an export, not a reconstruction.
Hope is not a breach response plan. Take the free readiness assessment and see whether your current program would survive a 72-hour test.
Any unauthorised processing of personal data, or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access that compromises its confidentiality, integrity or availability. There is no materiality threshold, so a misdirected export, a misconfigured bucket or a lost laptop with unencrypted records can each qualify.
Two parties. Every affected Data Principal, without delay and in plain language: what happened, the likely consequences, what you are doing, what they can do, and a human contact. And the Data Protection Board: an initial intimation promptly on becoming aware, followed by a detailed report within 72 hours.
The nature and extent of the breach, the personal data involved, the timeline and circumstances, the remedial measures taken, and findings about who was responsible. Where justified, a Data Fiduciary can seek extended time from the Board for the detailed report, but the initial intimation is still owed promptly.
Up to ₹200 crore under the Act's Schedule. This is separate from the up-to-₹250-crore exposure for failing to maintain reasonable security safeguards, so a single breach can generate two independent penalty events: one for the safeguard failure and one for the notification failure.
Those that meet it keep a live map of where personal data lives so scoping takes hours, hold pre-approved notification templates in every language they serve, and rehearse with a tabletop exercise twice a year. Most teams find the real bottleneck is drafting and approval, not detection.
General guidance on the DPDP Act, 2023 and DPDP Rules, 2025 — not legal advice.
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