The largest threats to compliance can be found in common places such as cloud dashboards, procurement lists, email inboxes, and all the smaller SaaS tools that are frequently disregarded. To put it simply, third-party vendors are where the real exposure occurs.
While we continue to concentrate on the obvious aspects of DPDPA, including strengthening consent processes, updating privacy notices, and tightening retention regulations, there are also some more fundamental problems that may subtly lead to a breakdown in compliance. These problems typically arise when personal information enters unmonitored, improperly governed, or poorly understood external systems.
One thing the law makes clear, however, is that your company is still accountable for what your vendors do with personal information. This article will explore the data challenges and risks related to the third party in association with the new DPDP Rules.
The sheer quantity of external tools that most businesses use on a daily basis including HR platforms, CRMs, payment gateways, email marketing tools, AI plugins, customer support systems, cloud storage, and more, is where it all begins. Each of these tools interacts with personal information in a different way. Nearly none were reviewed with privacy-by-design in mind, and many were added years ago, long before anyone considered DPDP compliance.
Once you start mapping where data goes, the uncomfortable questions appear including who has access to this data, where it is stored, how many copies of it exist, and whether the vendor can truly delete all of those copies if requested.
These conversations are no longer theoretical. You must respond with confidence and clarity under DPDP.
Another challenge surfaces when organizations dig into vendor contracts. Most agreements were written with operational convenience in mind, not regulatory accountability. They rarely specify how data should be processed, how breaches should be reported, or what must happen when a customer requests deletion.
Vendors often use global infrastructure, meaning data may travel through regions you didn’t know were in the path. Some use subcontractors you’ve never heard of. And almost every contract needs re-negotiation, something vendors are not always enthusiastic about.
This isn’t just legal cleanup. It’s a structural shift in how organizations think about trust.
DPDP also exposes another reality about carrying a legal responsibility even if the breach happens on the vendor’s end. This is where companies often discover that their incident response plan doesn’t extend beyond their own four walls. Many don’t have access to the vendor’s logs, or the right to demand forensic evidence, or clarity on who reports what to whom.
The result is a scramble during the one moment when time matters most.
If there is a single DPDP requirement that consistently breaks at the vendor level, it is data deletion. Many third parties struggle to delete information on command because of the way their systems were originally designed. They have long-term backups, shared environments, old logs that auto-archive, and data spread across multiple regions.
DPDP doesn’t care about those constraints. When a user asks for deletion, it has to happen, everywhere!
What’s becoming increasingly clear is that DPDP is not just a privacy reform; it’s a supply-chain reform. Compliance succeeds or fails based on how well organizations understand and govern their extended digital ecosystem.
Companies will not fail to achieve DPDP compliance due to a lack of care from their internal teams. Instead, they will fail because the infrastructure surrounding them was not designed to support this level of accountability.
Fixing that requires visibility, collaboration, and in many cases, rethinking long-standing vendor relationships. At last, the organizations that act early by mapping flows, rewriting contracts, and testing deletion and breach scenarios, will be the ones that stay ahead of the curve.
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