The DPDP Rules are phasing in through 2026 and 2027. Most organisations are working towards full operational compliance by May 2027.

What this means for you

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Software and app companies

Software companies usually have the best technical controls and the worst documentation. The access policy exists in someone's head, the logging captures far more than anyone intended, and the vendor list has never been written down.

The Act applies to every organisation that holds personal data. What reasonable looks like changes a great deal by sector, and this is what it changes to here.

The position

What makes this sector different

A product company holds end user data in production, copies of it in analytics and logging, more copies in backups and staging, and fragments of it inside every third party service the product calls. Engineers understand all of this. It has usually never been recorded anywhere a non engineer could read.

There is also a second role to deal with. If you process data on behalf of your business customers, you carry obligations to them as well as to your own users, and your customers will increasingly ask you to evidence that.

Discovery

Where personal data usually sits

Drawn from engagements and from the questions that come up most often on first calls in this sector.

Software and app companies
SystemWhat it holdsWhat usually needs attention
Production databaseEnd user accounts, profile data, usage records, contentEngineers hold standing production access with no logging or review
Analytics and loggingDevice identifiers, IP addresses, session recordings, error payloadsLogs capture far more personal data than the product needs
Backups and stagingFull copies of live dataTest environments run on real customer data
Third party servicesData sent to payment, messaging, support and infrastructure providersNo written list of which vendors receive personal data
AI featuresPrompts, uploaded files and conversations sent to model providersShipped before anyone read the provider's data terms
Customer accountsData your business customers put into your productNo data processing terms offered to customers who ask for them
Specific risks

What we look at first here

Staging on production data. Convenient, universal, and the fastest route to an exposure that is difficult to explain.

Over-collection in logs. Error payloads routinely contain whole request bodies, which means personal data sits in a logging system nobody treats as sensitive.

Standing production access. Access that was granted during an incident two years ago and never revoked.

AI features added fast. A feature that sends user content to a model provider changes where your data goes, and the decision is often made inside a sprint.

Customers asking you to evidence compliance. Increasingly a sales blocker, and the answer takes weeks to assemble if nothing was recorded.

The engagement

Which steps carry the most weight

The full sequence is on the engagement page. In this sector, these three usually do the heavy lifting.

Priority

Gap Analysis

Where you process on behalf of business customers, your obligations differ from where you decide things yourself. This gets settled first because it changes everything after it.

Priority

Discovery and mapping

Mapping runs through the codebase and the infrastructure as much as through interviews, including what the logs and the third party calls actually carry.

Priority

Compliance Support

Data processing terms you can offer customers, an internal access policy, retention and deletion that works across backups, and notices that match the product.

If you sell to customers in Europe or the United Kingdom, more than one framework applies to the same systems. We build one control set and record how it answers each, so you run one programme rather than two.

Other sectors

Not quite your business?

Every engagement is scoped to what you actually run, so none of these pages will match you exactly.

Start here

Thirty minutes, and you will know where you stand.

Tell us what your business runs on. We will tell you which gaps matter most, whether or not you engage us.