Section 3(b), not in force yet, reaches processing outside India in connection with any activity related to offering goods or services to people in India. The Act creates no local presence duty beyond the India based Data Protection Officer of a notified Significant Data Fiduciary, and section 37 blocking, in the same 18 month group, is the route against a company with no Indian assets.
Section 3 carries no turnover, headcount or user threshold, so a 2 person company is inside the Act once section 3 commences on a computed 13 May 2027. That date is interpretation until officially confirmed. Size still decides which duties bite, in 3 named places, and section 17(3) names startups without exempting a single one.
The Board complaint route is not open yet: sections 28 to 34 commence on a computed 13 May 2027, interpretation until officially confirmed. What starts an inquiry under section 27, the 6 month inquiry clock, the section 33(2) factors and the 60 day appeal.
DPDP Rule 7, not in force yet, starts 2 clocks on awareness of a breach: intimation without delay, then detailed information to the Board within 72 hours. Computed commencement is 13 May 2027, interpretation until officially confirmed, and the intimation goes to each affected Data Principal and to the Board.
The DPDP obligations belong to your organisation and not to the CTO, and none of these rules is in force yet: all are computed to commence 13 May 2027. That date is interpretation until officially confirmed. Engineering usually leads the technical half: safeguards, retention timers, breach detection, consent withdrawal paths and rights machinery, with the cross functional dependencies made explicit.
A small team's path through the DPDP framework: settle applicability, map your data, and build the 5 duty clusters in dependency order while the runway lasts.
Section 6, not in force yet, sets 5 qualities, a clear affirmative action, a necessity limit and a proof burden that lands on you. 10 sub sections and 4 illustrations, read clause by clause.
Transfers out of India are permitted by default under Rule 15, which is not in force yet. But Rule 13(4) does impose localisation, once it commences, on Significant Data Fiduciaries for data the Central Government specifies, including the traffic data pertaining to its flow.