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GCC COMPLIANCE

GCC DPDP Gap Assessment

Certified ≠ compliant
8
Compliance Domains
Upto 41
Diagnostic Controls
>15 mins
To Complete
211
days to full DPDP compliance

Deadline: 13 May 2027

₹250 crore maximum penalty per instance
GCC COMPLIANCE

GCC DPDP Gap Assessment

Certified ≠ compliant
8
Compliance Domains
Upto 41
Diagnostic Controls
>15 mins
To Complete

211

days to full DPDP compliance

Deadline: 13 May 2027

₹250 crore maximum penalty per instance

Why this assessment

1.0
2.0
Most GCCs today: 2.5 - 3.0
3.0
GCC 4.0

Most centres are strong on functional excellence and early AI adoption, but short of the autonomous, self-optimizing model GCC 4.0 describes. This tool turns the framework into a diagnostic so you can see exactly where the distance is.

Strong certifications are not Indian law

ISO 27001 and SOC 2 are control frameworks, and ISO 27701 is built around GDPR. DPDP adds obligations they do not address.

Roles

Who is the Data Fiduciary and who is the Processor, under the s.17(1)(d) outsourcing exemption

Lawful basis

Consent or ‘legitimate use’, not ‘legitimate interest’

Breaches

Intimation to every affected person, with no materiality threshold

Evidence

One-year log retention, a 90-day grievance ceiling, children’s data rules and Board-facing proof

Strong certifications are not Indian law

ISO 27001 and SOC 2 are control frameworks, and ISO 27701 is built around GDPR. DPDP adds obligations they do not address.

Roles

Who is the Data Fiduciary and who is the Processor, under the s.17(1)(d) outsourcing exemption

Lawful basis

Consent or ‘legitimate use’, not ‘legitimate interest’

Breaches

Intimation to every affected person, with no materiality threshold

Evidence

One-year log retention, a 90-day grievance ceiling, children’s data rules and Board-facing proof

What gets assessed

Eight compliance domains
Applicability

Scope, Parent ↔ GCC Roles & Data Inventory

Which personal data you process, whose it is, and whether the GCC is a Data Fiduciary or a Data Processor for each flow
Lawfulness

Lawful Basis, Notice & Consent

Processing only on consent (s.6) or a closed list of legitimate uses (s.7), with clear notice
Rights

Data Principal Rights & Grievance Officer

Access, correction, erasure and nomination rights, with grievance redressal inside 90 days
Rule 6

Security Safeguards & Logging

Reasonable safeguards under s.8(5): encryption, access control, monitoring, and one-year log retention
Rule 7

Breach Detection & Notification

Every breach, with no materiality threshold, reported to each affected person and to the Board
Storage Limitation

Retention, Erasure & Minimisation

Erase personal data once its purpose is served or consent is withdrawn, including at processors
Third Parties

Processors, Intra-group & Cross-border

Accountability for processors, valid contracts, intra-group sharing and cross-border flows
Accountability

Governance, Accountability & Special Categories

Named ownership, training and evidence, plus children’s data and Significant Data Fiduciary readiness

What gets assessed

Eight compliance domains
Applicability

Scope, Parent ↔ GCC Roles & Data Inventory

Lawfulness

Lawful Basis, Notice & Consent

Rights

Data Principal Rights & Grievance Officer

Rule 6

Security Safeguards & Logging

Rule 7

Breach Detection & Notification

Storage Limitation

Retention, Erasure & Minimisation

Third Parties

Processors, Intra-group & Cross-border

Accountability

Governance, Accountability & Special Categories

What gets assessed

Eight compliance domains
Applicability

Scope, Parent ↔ GCC Roles & Data Inventory

Which personal data you process, whose it is, and whether the GCC is a Data Fiduciary or a Data Processor for each flow
Lawfulness

Lawful Basis, Notice & Consent

Processing only on consent (s.6) or a closed list of legitimate uses (s.7), with clear notice
Rights

Data Principal Rights & Grievance Officer

Access, correction, erasure and nomination rights, with grievance redressal inside 90 days
Rule 6

Security Safeguards & Logging

Reasonable safeguards under s.8(5): encryption, access control, monitoring, and one-year log retention
Rule 7

Breach Detection & Notification

Every breach, with no materiality threshold, reported to each affected person and to the Board
Storage Limitation

Retention, Erasure & Minimisation

Erase personal data once its purpose is served or consent is withdrawn, including at processors
Third Parties

Processors, Intra-group & Cross-border

Accountability for processors, valid contracts, intra-group sharing and cross-border flows
Accountability

Governance, Accountability & Special Categories

Named ownership, training and evidence, plus children’s data and Significant Data Fiduciary readiness

What gets assessed

Eight compliance domains
Applicability

Scope, Parent ↔ GCC Roles & Data Inventory

Lawfulness

Lawful Basis, Notice & Consent

Rights

Data Principal Rights & Grievance Officer

Rule 6

Security Safeguards & Logging

Rule 7

Breach Detection & Notification

Storage Limitation

Retention, Erasure & Minimisation

Third Parties

Processors, Intra-group & Cross-border

Accountability

Governance, Accountability & Special Categories

How it works

1

DPDP briefing

A two-minute read of the Act and what it means for a GCC
2

GCC profile

Certifications held, your likely DPDP role, and Indian Data Principals processed
3

Rate controls

Score each control across D1 to D8
4

Part 1 report

Readiness score, scorecard, top gaps and brief fixes
5

Part 2 report

Detailed actions with Act and Rules references, owners and timelines

Part 1: free, instant

Your readiness score, key requirement scorecard, and the clearly visible gaps with brief steps to fix them

Part 2

Detailed actions with Act and Rules references, owners and timelines
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Ready to see where you stand?

Start with a two-minute briefing, then go straight into the self-assessment. About 15 minutes in total
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