30-60-90 Day DPDP Implementation Plan for SMEs

An SME does not need a hundred-page policy library on day one. It needs an accurate data map, controlled access and workable incident response.

What the organisation should understand

• The DPDP framework is phased. The 14 November 2025 commencement notification brought specified institutional and enabling provisions into force immediately; section 6(9), section 27(1)(d) and rule 4 follow after one year; most operating duties and rules follow eighteen months after Gazette publication. As of 22 June 2026, readiness should distinguish current law from future-state DPDP controls.
• Readiness should prioritise current cyber, sector, contract and consumer duties while building toward scheduled DPDP provisions.
• The first thirty days should establish ownership, scope, inventory and immediate high-risk fixes.
• Days thirty-one to sixty should build notices, consent, vendor, access, retention and rights workflows.
• Days sixty-one to ninety should test controls, remediate failures and obtain management decisions.

For the connected rule, example or next step, see 90-Day DPDP Readiness Plan.

The five-point review

Practical example

How to apply the framework

Use a small number of owned deliverables. A policy without a system change is incomplete.

Test real scenarios: deletion request, vendor breach, employee exit, child account and marketing withdrawal.

Operating workflow

Define the processing or incident precisely

Identify the people, data, system, purpose, owner, vendor and transaction or event. Review people, inventory and priority together. Do not start from a policy template or software feature; start from what the business and system actually do.

Separate current duties from future-state DPDP readiness

Apply the 14 November 2025 commencement notification provision by provision. Continue complying with currently operative IT, CERT-In, telecom, banking, insurance, employment, consumer, contract and criminal-law requirements. Build the future DPDP process now, but do not describe a scheduled rule as already legally operative.

Preserve proof and improve the system

Keep the approved decision, notice or workflow version, access or event logs, vendor evidence, user communications and remediation record. Update product design, role access, retention, support scripts or incident playbooks so the same weakness does not recur.

Action checklist

• Days 1–30: appoint owners and map data.
• Days 1–30: fix open access and backup risks.
• Days 31–60: update notices and vendor terms.
• Days 31–60: build rights and retention.
• Days 61–90: run simulations.
• Days 61–90: approve continuing roadmap.

Evidence to keep

• 90-day plan
• Data and vendor inventory
• Updated notices
• Procedures
• Exercise reports

Warning signs

Finin2min takeaway