An educational guide, not legal advice. Main obligations for apps take effect on 13 May 2027.
§DPDP for AppsIndia's data protection law, for app teams

Security safeguards

The minimum security measures in Rule 6 of the DPDP Rules for mobile apps, from encryption and access controls to one-year logs and processor contracts.

Act s.8(4), s.8(5) · Rule 6 · Takes effect 13 May 2027

Short answer: From 13 May 2027, an app must take reasonable security safeguards to prevent personal data breaches (s.8(5)), and it stays responsible for processing its processors carry out on its behalf (s.8(1)). Rule 6 lists the minimum measures, such as encryption or masking, access controls, monitoring logs kept for one year, backups and security clauses in processor contracts. Failure carries the Act's highest penalty, up to ₹250 crore.

What are reasonable security safeguards under the DPDP Act?

Reasonable security safeguards are the technical and organisational measures a Data Fiduciary must take to prevent a personal data breach, with Rule 6 setting the minimum (s.8(4), s.8(5), Rule 6).

  • Personal data breach: any unauthorised processing, or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access, that compromises the confidentiality, integrity or availability of personal data (s.2(u)).
  • Virtual token: a token mapped to personal data, listed in Rule 6(1)(a) as a security measure alongside encryption, obfuscation and masking.
A Data Fiduciary must implement appropriate technical and organisational measures (s.8(4)) and take reasonable security safeguards to prevent a personal data breach (s.8(5)). Rule 6 sets the minimum measures.

What does Rule 6 require at a minimum?

Rule 6(1) lists seven minimum measures: encryption, obfuscation, masking or virtual tokens; access controls; logs, monitoring and review; backups and continuity; one-year retention of logs and personal data for investigating unauthorised access; security provisions in processor contracts; and appropriate technical and organisational measures.

RuleMinimum measureTypical app control
6(1)(a)Encryption, obfuscation, masking or virtual tokens mapped to personal dataEncryption in transit and at rest, tokenised identifiers
6(1)(b)Access controlsRole-based access, least privilege, MFA for staff
6(1)(c)Logs, monitoring and reviewAccess logs, alerting, periodic review
6(1)(d)Backups and continuity measuresBackups, restore testing, incident runbooks
6(1)(e)Retain logs and personal data for one year to detect and investigate unauthorised accessLog retention policy of at least one year
6(1)(f)Contractual provision with Data Processors for safeguardsSecurity clauses in SDK and cloud contracts
6(1)(g)Appropriate technical and organisational measuresPolicies, training, ownership

The typical controls in the third column are common industry examples, not text from the Rules.

Does hashing or masking take data outside the Act?

Not on the face of the Rules. Rule 6(1)(a) lists masking, obfuscation and virtual tokens mapped to personal data as security measures, not as ways of taking data outside the Act.

  • Interpretation: law firm commentary (AMLEGALS) reports that hashing does not take an identifier outside the Act if it remains linkable to an individual. No Board or court ruling exists yet.

Are processors covered?

Yes. The app is responsible for processing carried out on its behalf by a Data Processor, irrespective of any agreement to the contrary (s.8(1)). Rule 6(1)(f) requires a contractual provision with each processor for reasonable safeguards. See processors and SDKs.

How does this sit with existing Indian law?

  • IT Act s.43A: compensation for failure to protect sensitive personal data is omitted by s.44(2) of the DPDP Act, which takes effect on 13 May 2027.
  • Interpretation: until 13 May 2027, s.43A of the IT Act and the IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 continue to apply, because s.44(2) has not yet commenced. The commencement notification does not say this expressly.
  • CERT-In Directions (28 April 2022): a separate regime under the IT Act, already in force, requiring specified cyber incidents to be reported to CERT-In within 6 hours and ICT system logs to be kept for 180 days in India.

What is the penalty for weak security?

Failure to take reasonable security safeguards to prevent a personal data breach carries a penalty of up to ₹250 crore, the highest amount in the Schedule (Schedule item 1). The Board sets the amount after an inquiry, considering factors such as the gravity and duration of the breach and the mitigation taken (s.33). See the penalties page.

What this means for your app

These are practical steps teams commonly consider. They are not a guarantee of compliance.

  • Consider mapping each Rule 6(1) measure to a named control and owner, and recording evidence that it operates.
  • A common approach is encryption in transit and at rest for all personal data, with tokenised or hashed identifiers in analytics pipelines, while treating these as safeguards rather than exemptions.
  • Review staff and vendor access to production data and remove access that is not needed.
  • Consider setting log retention to at least one year for systems that process personal data, to meet Rule 6(1)(e) and Rule 8(3).
  • Add security clauses to contracts with cloud providers, SDK vendors and other processors (Rule 6(1)(f)).
  • Test backups and incident response, and link the runbook to the breach notification steps.
  • Track progress in the readiness checklist.
FAQ

Common questions

What is the maximum penalty for a security failure under the DPDP Act?

Up to ₹250 crore for failing to take reasonable security safeguards to prevent a personal data breach (Schedule item 1). It is the highest penalty in the Schedule.

Does the DPDP Act require encryption?

Rule 6(1)(a) lists encryption, obfuscation, masking or virtual tokens as minimum measures for securing personal data. An app is expected to use appropriate measures from that list.

How long must security logs be kept?

Rule 6(1)(e) requires logs and personal data to be retained for one year for detecting and investigating unauthorised access. Rule 8(3) separately sets a one-year minimum for processing logs.

Is the app responsible for its SDK vendors' security?

The Data Fiduciary is responsible for processing on its behalf by a Data Processor, irrespective of any agreement to the contrary (s.8(1)). It must also have a contractual provision requiring processors to take reasonable safeguards (Rule 6(1)(f)).

Do the CERT-In rules still apply alongside the DPDP Act?

Yes. The CERT-In Directions of April 2022 are made under the IT Act and are a separate regime. They require specified cyber incidents to be reported to CERT-In within 6 hours.

When does the DPDP Act apply to apps?

Most obligations for apps, including notice, consent, security, breach notification, children's data and user rights, take effect on 13 May 2027. The Rules were notified on 13 November 2025 with an 18-month phase-in.