Buyer's guide
Two very different things are sold as a "DPDP audit". One is a readiness assessment, which tells you where you stand and what to fix. The other is the independent data audit that attaches to Significant Data Fiduciaries as a statutory obligation. Buying the first while believing you have satisfied the second is a common and expensive mistake.
The distinction decides who can perform it and what it is worth.
Not policies. Evidence that the policies are what actually happens.
Ask what they will test rather than what they will review — testing implies sampling live systems, reviewing implies reading documents. Ask for a redacted example of a previous report. Ask who signs it and what their standing is. And ask what happens when they find something serious, because an auditor who negotiates findings is not providing assurance.
Audit cost tracks evidence readiness almost exactly. An organisation whose inventory, RoPA, consent records and rights logs are generated by a system spends a fraction of what one reconstructing them from spreadsheets spends, and gets a better report. That is the practical argument for operating the programme in a platform rather than assembling it annually.
An independent data audit is an obligation attaching to Significant Data Fiduciaries. Any organisation can commission a readiness assessment, and most should before they need the statutory one.
Not for the independent audit. Independence from the programme being assessed is the point of the obligation, and a vendor auditing a system it supplied is not independent of it.
Whether the inventory matches reality, whether each activity has a recorded lawful basis, whether consent binds to the notice actually shown, whether withdrawal stops downstream processing, and whether rights requests were answered within the statutory period — tested against evidence, not policy documents.
Jupinder Bedi — Jupinder writes on data protection practice at ProtectComply, with a focus on how obligations translate into system behaviour.
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