DPDP Act 2023 Compliance

FieldGovern's official clause-by-clause compliance mapping — purpose limitation, consent, data principal rights, breach reporting. For a plain-language explainer of the law itself, see our DPDP Act guide for researchers; to compare survey tools on DPDP fit, see DPDP-compliant survey software.

DPDP 2023 Ready Data Localisation Consent Audit Trail Breach Notification

What the DPDP Act requires

The Digital Personal Data Protection Act 2023 (DPDP) governs how organisations collect, process, store, and share personal data of Indian citizens. For field data collection — surveys, enumerations, panel studies — the key obligations are:

Lawful Purpose & Consent

Personal data must be collected for a specific, clear purpose. Consent must be free, specific, informed, and unconditional — and must be recorded.

Data Minimisation

Only data necessary for the stated purpose may be collected. Extra fields that aren't needed = liability.

Data Principal Rights

Respondents have the right to access, correct, and erase their data. Organisations must have a mechanism to honour these requests.

Breach Notification

Data breaches must be reported to the Data Protection Board and affected data principals within 72 hours of discovery.

Data Fiduciary Obligations

Organisations that decide the purpose and means of processing (data fiduciaries) must appoint a Data Protection Officer if required, and publish a privacy policy.

Data Processing Agreements

When engaging a data processor (like FieldGovern), a written DPA is required that specifies the scope, purpose, and security obligations.


FieldGovern's DPDP compliance mapping

Below is a clause-by-clause mapping of the DPDP Act's obligations to FieldGovern's implemented controls.

DPDP Obligation FieldGovern Control Status
S.6 — Consent
Free, specific, informed, unconditional consent before collection
Consent question type in form builder. Consent timestamp + IP logged per submission. Public-survey link includes consent preamble. Implemented
S.6(6) — Consent withdrawal
Data principal can withdraw at any time
Soft-delete endpoint for submission data. Org admins can action withdrawal requests against respondent ID/phone. Implemented
S.8 — Purpose limitation
Data used only for stated purpose
Form-level "data purpose" field (JSONB). Export API tags all exports with purpose + user ID in audit log. Implemented
S.8(3) — Data accuracy
Data must be accurate and complete
FgCleaner QC engine flags duplicate, incomplete, and implausible submissions before approval. Approval workflow prevents inaccurate data from becoming "official". Implemented
S.8(7) — Storage limitation
Data not retained beyond purpose
Tenant-level retention policy setting (days). Scheduler auto-archives submissions past retention. Configurable per program. In roadmap
S.11 — Right to access
Data principal can request their data
Export by respondent ID/phone exports all submissions for that individual. CSV/PDF output. Implemented
S.12 — Right to correction/erasure
Data principal can correct or erase their data
Org admins can edit or delete individual submission records. Audit log records the action, actor, and timestamp. Implemented
S.13 — Right to grievance redressal
Mechanism to raise and address grievances
Grievance email configurable per-tenant (shown in privacy policy template). Response SLA tracked by org admin. Manual process
S.8(5) — Data breach notification
Notify Board + data principals within 72h
Sentry real-time error alerting. Breach notification template included in DPA (see link below). Manual escalation process. Template provided
S.9 — Children's data
Verifiable parental consent for minors
Date-of-birth field auto-flags a submission as a minor; a linked guardian-consent question is required. Minor records are hidden from the default view and excluded from AI-facing analysis unless an admin explicitly opts in. Implemented
S.8(4) — Security safeguards
Appropriate technical + organisational measures
JWT HS256 + bcrypt. Database-level row-level security enforces tenant isolation via a restricted, non-superuser database role — not application-code filtering alone. TLS 1.2+/HSTS everywhere. OPFS encrypted offline storage. Tamper-evident, hash-chained audit log with anomaly detection. Implemented
Data localisation
Personal data of Indian citizens stored in India
Deployable on Oracle Cloud India (Mumbai/Hyderabad), Hetzner India, or any on-premise server. Data never leaves your chosen region. Self-hosted option
Data Processing Agreement
Written DPA with processor required
Standard DPA template available below. Can be customised for each client engagement. Template available

Sub-processors

Third parties FieldGovern may share data with while providing the service, and where each one processes it.

Sub-processorPurposeCountry
Hosting Application, database and media storage See our Trust Centre for the current region
Google (Sheets, Drive, OAuth) Optional live Sheets sync (opt-in per form, identifier fields excluded by default), optional Drive-backed media storage, "Sign in with Google" US / global
SMS / WhatsApp / Telegram Optional notifications — opt-in per organisation India (MSG91) / US (Meta)
Razorpay Subscription payment processing India
Sentry Application error monitoring Configurable
PostHog Product usage analytics — not submission/respondent data US

This list updates automatically when the platform's AI provider changes. Org admins can disable AI processing entirely for their organisation from Settings — see the "AI Features" toggle.


FieldGovern's Grievance Officer

Per the DPDP Rules, 2025, FieldGovern publishes a named point of contact for data-protection grievances relating to our own processing as a company — account, billing, and website data. This is separate from your own organisation's grievance channel for your respondents, which you configure independently in Settings.

Manjunath YN

Grievance Officer, FieldGovern
Email: manjunath@dataworx.co.in


Built-in compliance checklist for field teams

Before deploying a survey program, run through this checklist in FieldGovern:


Frequently asked questions

Is FieldGovern a data fiduciary or data processor?

FieldGovern is a data processor. Your organisation — the NGO, research institute, or government body running the survey — is the data fiduciary. You determine the purpose and means of processing; we process data on your instructions.

Can we self-host to keep data on our own servers?

Yes. FieldGovern is fully self-hostable via Docker Compose on any Linux server in India. Your data never leaves your infrastructure. This satisfies both DPDP data localisation requirements and internal IT policies at most government bodies.

What happens if there is a data breach on FieldGovern's hosted service?

We will notify the affected tenant within 6 hours of discovery. Our breach notification template (included in the DPA) guides you through notifying the Data Protection Board and affected data principals within the 72-hour DPDP window. Sentry monitors all backend errors in real time.

Do we need a DPA if we use FieldGovern's hosted service?

Yes — the DPDP Act requires a written agreement between data fiduciary and data processor. We provide a standard DPA template that can be signed digitally. Download it below.

Can FieldGovern export a consent audit trail for regulators?

Yes. The audit log export (CSV) includes every consent capture event: submission ID, respondent phone (hashed), form version, timestamp, and GPS coordinates of the device at time of consent.

Download the DPA template

Our standard Data Processing Agreement is pre-filled with FieldGovern's security commitments and DPDP obligations. Have your legal team review and sign digitally.

View DPA Template Start Free Trial

Related reading

DPDP-compliant survey software comparing vendors on DPDP fit DPDP Act 2023 explained for researchers plain-language guide + 30-day checklist Security overview encryption, hosting, audits Trust Centre sub-processors, DPA, status