Why DPDPA Compliance is a Startup Essential
The Digital Personal Data Protection Act, 2023 (DPDPA), marks a significant shift in how businesses in India handle personal data. While most discussions around privacy laws focus on big tech, the reality is that DPDPA applies equally to small startups, solo founders, and bootstrapped teams. If your business collects email addresses, phone numbers, or any kind of identifiable user data even through something as basic as a Google Form you're legally bound by the provisions of this Act. And with penalties reaching up to ₹250 crore, non-compliance isn’t an option. But complying with DPDPA doesn't have to be overwhelming. In fact, many startups already follow good practices that align with the law they just need to document and refine them. This blog offers a simplified, step-by-step checklist to help you build DPDPA compliance into your startup DNA from day one, without hiring expensive consultants or legal teams.
Understanding What Counts as Personal Data
DPDPA defines personal data as any data about an individual who is identifiable by or in relation to such data. This includes obvious identifiers like names, phone numbers, addresses, Aadhaar details, and email IDs, but also extends to indirect identifiers such as device IPs, cookies, location data, and behavioural information like browsing patterns. If you're collecting any of this through your website, mobile app, or third-party tools, you're officially a "Data Fiduciary" under DPDPA and required to comply with its provisions. Many solopreneurs and small businesses assume privacy law doesn’t apply to them until they realize they’re tracking user behaviour through Facebook pixels or sending bulk emails to customers without consent. The first step to compliance is accepting that your business processes personal data, and that it comes with legal and ethical responsibilities.
Collecting Consent, the Right Way
Under DPDPA, user consent must be free, specific, informed, unambiguous, and capable of being withdrawn. This means startups need to move beyond default opt-ins and ambiguous sign-up forms. You must clearly inform users about what data you’re collecting, why you need it, how long you'll retain it, and what rights they have regarding their data. If your app asks for location access, you must explain what features depend on it. If you're collecting email addresses, you should clarify whether it's for account verification, newsletters, or both and allow users to choose. More importantly, the option to say “no” should be just as easy as saying “yes.” Building clear and transparent consent notices into your user journey not only makes you compliant but also earns long-term user trust.
Assigning a Grievance Contact (Yes, Even Solo Founders)
DPDPA mandates that every Data Fiduciary provide a point of contact to address user concerns. For a small business or solo founder, this doesn’t mean hiring a separate grievance officer. You can simply designate yourself or a team member and include a contact email such as privacy@yourstartup.in in your privacy policy. You must ensure that user complaints or data requests are acknowledged and resolved within seven working days. Even if you're using off-the-shelf tools or platforms, you're still responsible for the data you collect through them. Having a clear process for responding to privacy-related queries is not just a legal formality it's a key element of a privacy-first culture.
Respecting Users' Data Rights
DPDPA grants users referred to as Data Principals several rights, including the right to access their data, correct it, withdraw consent, and request deletion. As a startup, you need to create simple ways for users to exercise these rights. This doesn’t require a high-tech portal even a basic form or email-based system will suffice, as long as you can process requests promptly and respectfully. For example, if someone asks you to delete their account or stop sending them emails, you must comply and confirm the action. Treat these requests seriously and document your responses to maintain accountability. As you scale, consider automating parts of this process using privacy-friendly tools and CRMs.
Updating Your Privacy Policy
One of the most overlooked parts of compliance is a transparent, user-friendly privacy policy. This document should clearly explain what personal data you collect, why you collect it, who you share it with (if anyone), how long you retain it, and what rights users have under DPDPA. It must also include the grievance redressal mechanism and contact information. The policy should be visible, accessible, and written in plain language. Avoid complex legal jargon that your average user can’t understand. Many startups benefit from using a layered policy where the main points are summarized in short, bulleted sections, followed by a detailed version for legal purposes. If you don’t have a privacy policy yet, now is the time to write one and publish it on your website or app.
Ensuring Data Security on a Budget
DPDPA doesn’t require startups to implement military-grade cybersecurity, but it does require “reasonable security safeguards.” This includes basic but critical practices such as using HTTPS encryption, storing passwords securely (hashed and salted), limiting access to personal data within your team, and regularly updating software or plugins. Even if you’re relying on tools like Google Sheets, Typeform, or Firebase, you’re still responsible for how data is protected. Document your security measures, conduct internal audits periodically, and make sure everyone on your team is aware of best practices
Avoiding Overcollection of Data
One of the core principles of DPDPA is data minimization. Startups often fall into the trap of collecting too much data “just in case” but this increases both your risk and your responsibility. If you don’t need a user’s date of birth, don’t ask for it. If you can allow users to check out as guests, don’t force account creation. Collect only the data that’s essential to your product or service, and explain why you're collecting it. Less data means fewer compliance headaches, smaller attack surfaces, and better user relationships. Being intentional with data collection also reflects maturity in your product design process.
Privacy as a Startup Superpower
Many early-stage startups assume privacy is a legal burden something to worry about only when they scale. But in truth, DPDPA compliance can be your competitive advantage. Being transparent, ethical, and responsible with user data sets you apart in a crowded market. It builds trust, reduces the risk of penalties, and prepares you for future global expansion. The good news is that compliance doesn't require legal teams or complex software. With the right mindset, clear documentation, and this checklist, even solo founders can meet DPDPA requirements effectively. Privacy-first businesses aren’t just compliant they’re better designed, more sustainable, and far more user-friendly.
