DPDP Act AI readiness checklist: what your DPO will ask about your AI
The BiltIQ DPDP AI readiness checklist is a free PDF for Indian organisations that use AI on personal data. It walks through where AI calls go, processors and sub-processors, consent, children's data, logs, breach response and the roles involved when you own or subscribe to AI. It is a working aid, not legal advice; confirm duties with counsel.
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- Topics, from mapping your AI calls to breach response
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- One PDF, vendor-neutral; not legal advice
- Free
- Written for data protection officers, CIOs, CISOs and legal teams
- DPO
- Agent OS outbound calls, blocked by default (platform gate)
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What's inside the DPDP AI checklist
- Map your AI calls. Every tool that sends prompts or documents outside your network, and where it sends them.
- Processors and sub-processors. Who processes personal data for you, under which contract, and who they pass it to. You answer for what they do on your behalf.
- Consent and notice. Whether your notices cover AI use, and how consent is recorded and withdrawn.
- Children's data. When verifiable consent from a parent or lawful guardian is needed, which exemptions in the DPDP Rules may apply, and what tracking to switch off.
- Logs and audit. What your AI systems record, who can read it, and for how long.
- Approvals. Which AI actions need a named person to sign off.
- Breach response. Who decides, who notifies, and in what order.
- Own it or subscribe. How the roles change when the AI runs on your servers or on a provider's.
- Timeline and penalties. Where to check when each duty applies (meity.gov.in), and the duties that carry penalties.
Who the checklist is for
Data protection officers, CIOs, CISOs and legal teams at Indian organisations that use, or plan to use, AI on customer or employee data. Under the Act, only Significant Data Fiduciaries must appoint a Data Protection Officer; every data fiduciary publishes a contact who can answer questions about its processing.
Why an AI vendor wrote a DPDP checklist
BiltIQ installs sovereign SI on its customers' own servers, so we answer these questions on every project. In Agent OS, outbound calls are blocked by default (platform gate), and irreversible and high-consequence actions pause for human approval. The checklist is vendor-neutral: it works whichever AI you use.
Key facts: DPDP AI readiness checklist
- The DPDP Act sets duties and penalties for how organisations handle personal data.DPDP Act 2023
- One PDF, free, vendor-neutral; not legal advice.BiltIQ
- In Agent OS, outbound calls are blocked by default; irreversible and high-consequence actions pause for human approval.BiltIQ code review, Oct 2026
FAQ
What does the DPDP AI readiness checklist cover?
It covers where your AI calls go, processors and sub-processors, consent and notice, children's data, logs and audit, approvals, breach response, and how roles change when you own or subscribe to AI. Each item is a question your data protection officer is likely to ask about any AI tool, with space to record your answer.
When do DPDP Act duties apply to our AI tools?
The DPDP Act's duties come into force in phases under notified rules, and the Act sets penalties for breaches. Check the current timeline on meity.gov.in and with your counsel. Generally, the Act covers your processing of digital personal data, including through AI tools, whether they run on your servers or on a provider's.
Is the DPDP AI checklist legal advice?
No. It is a working aid that helps your team find gaps and prepare questions for counsel and vendors. It does not interpret the Act for your case. Confirm your duties with a qualified lawyer, especially on children's data, cross-border transfers and breach notification, where the rules carry the most weight.
Does owning AI on our own servers settle DPDP for AI?
No, but it simplifies some questions. When your SI runs on your own servers, fewer outside processors touch personal data, and in Agent OS outbound calls are blocked by default. You still need notices, consent records, logs, access control and a breach plan. The checklist covers both the owned and the subscribed case.
Download the DPDP AI readiness checklist
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