DPDP enforcement deadline: May 2027Rules notified Nov 2025Penalty exposure up to ₹250 Cr
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⚠ DPDP Section 4 · Up to ₹200 Cr Penalty

DPDP Sensitive Data Audit — Identify High-Risk Personal Data Processing

Health records, biometrics, financial data, religious beliefs — DPDP’s strictest rules apply to sensitive personal data. Find out if you’re compliant.

4-step audit Instant risk score DPDP Section 4 aligned Full report ₹1,499
Step 1 of 4 — Sensitive Data Categories
25% complete
Step 1 — What Sensitive Data Do You Process?
Select every category your organisation collects or processes. DPDP Act Section 4 applies heightened obligations and up to ₹200 Cr penalties for each.
Health & Medical
Biometric Data
Financial Data
Identity & Government IDs
Sensitive Demographic Data
Step 2 — Collection & Consent Controls
For each sensitive data category you selected, answer 6 control questions. Use “Apply all: Yes” if a control applies uniformly across your organisation.
Step 3 — Incident History
Breaches involving sensitive personal data carry the highest DPDP penalty exposure. Answer honestly — this informs your risk score.
1Has any sensitive personal data been involved in a breach or incident in the last 3 years?
2Do you have a documented incident response plan covering sensitive data breaches?
3Have you tested the incident response plan in the last 12 months?
Step 4 — Organisational Controls
People, process, and policy controls reduce your overall DPDP liability. These factors also influence whether the Data Protection Board treats a violation as wilful or inadvertent.
1Is there a designated Privacy Officer or DPO responsible for sensitive data?
2Have employees handling sensitive data received specific DPDP training?
3Do you conduct Privacy Impact Assessments before new sensitive data processing begins?
4Do you have a data minimisation policy (collect only what is necessary)?
0
Sensitive data categories identified
₹0 Cr
Potential Section 4 penalty exposure

⚠️ 3 Most Critical Gaps Found

Categories Without Adequate Controls

Full breakdown of which sensitive data categories lack required consent, encryption, and access controls.

Biometric data
2 of 6 controls missing
Health records
3 of 6 controls missing
Financial data
1 of 6 controls missing
Aadhaar / PAN
2 of 6 controls missing
🔒

Full Category Breakdown Locked

See which categories fail and exactly which controls are missing

Get Your Full Sensitive Data Audit Report

Everything you need to fix your Section 4 exposure — per-category control gaps, consent templates, technical security checklist, and DPA requirements.

  • Complete inventory of all sensitive data categories identified
  • Per-category compliance status (6 controls × all categories)
  • Priority matrix: Critical gaps vs. fix this quarter vs. annual review
  • Consent framework recommendations for each category
  • Technical security controls checklist (encryption + access control matrix)
  • Vendor DPA requirements for sensitive data processors
  • Incident response checklist specific to sensitive data breaches
  • DPDP Section 4 cross-reference for every finding

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Quick Answer

What is sensitive personal data under the DPDP Act 2023? The DPDP Act 2023 does not use the term 'sensitive personal data' explicitly — instead, it applies a uniform framework to all personal data and allows the Central Government to notify specific categories of data that require additional protection. Historically, the SPDI Rules under the IT Act categorised passwords, financial information, health data, sexual orientation, biometric data, and caste information as sensitive. Organisations should treat these categories as high-risk under the DPDP Act and apply enhanced consent, security, and retention standards to them until the government issues specific notifications.

What is Sensitive Personal Data under the DPDP Act 2023?

Section 4 of the Digital Personal Data Protection (DPDP) Act 2023 defines sensitive personal data as health and medical records, biometric data (fingerprints, face, iris), financial information, government identity numbers (Aadhaar, PAN), caste or tribe membership, religious beliefs, political opinions, sexual orientation, and criminal records. Processing such data attracts the highest penalty tier — up to ₹250 Cr per violation.

Why do Indian companies need a Sensitive Data Audit?

Many organisations process sensitive personal data without realising it — biometric attendance systems, ESI/medical records, Aadhaar-linked KYC, and salary data are common examples. Without explicit consent mechanisms, encryption, access controls, and documented retention policies specific to each category, companies are exposed to direct Section 4 violations the moment DPDP enforcement begins (expected May 2027).

What is the penalty for mishandling sensitive personal data?

The DPDP Act prescribes penalties of up to ₹200–250 Cr for failure to implement adequate security safeguards for sensitive personal data. These penalties apply per category per violation, meaning an organisation that mishandles biometric data and health records without adequate controls could face cumulative exposure exceeding ₹400 Cr.

What controls are required for sensitive personal data under DPDP?

Organisations must obtain explicit, purpose-specific consent (separate from general T&C) for each sensitive data category; implement encryption at rest and in transit; restrict access on a need-to-know basis; maintain documented retention and deletion schedules; and execute Data Processing Agreements (DPAs) with every third-party vendor handling sensitive data.

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