Reasonable security safeguards
Encryption, access control, logging and backups expected of a FiduciaryEvery Fiduciary must protect personal data with reasonable safeguards - at minimum encryption or tokenisation, access controls, audit logs, backups for continuity, one-year log retention, contractual security clauses with Processors, and organisational measures.
Download full Rules (PDF)In plain English
Every Fiduciary must protect personal data with reasonable safeguards - at minimum encryption or tokenisation, access controls, audit logs, backups for continuity, one-year log retention, contractual security clauses with Processors, and organisational measures. This applies to data they hold and processing done on their behalf.
Key points
- Minimum: encryption, access control, logging, backups, contracts with Processors
- Retain logs and personal data for one year unless law requires otherwise
- Covers processing by Data Processors on the Fiduciary's behalf
This rule gives effect to Section 8 of the Digital Personal Data Protection Act, 2023.
Read the parent sectionOfficial rule text
Reproduced from the Gazette notification (G.S.R. 846(E), 13 November 2025).
6. Reasonable security safeguards. - (1) A Data Fiduciary shall protect personal data in its possession or under its control, including in respect of any processing undertaken by it or on its behalf by a Data Processor, by taking reasonable security safeguards to prevent personal data breach, which shall include, at the minimum, - (a) appropriate data security measures, such as securing of personal data through encryption, obfuscation, masking or the use of virtual tokens mapped to that personal data; (b) appropriate measures to control access to the computer resources used by such Data Fiduciary or such a Data Processor, wherever applicable; (c) visibility on the accessing of such personal data, through appropriate logs, monitoring and review, for enabling detection of unauthorised access, its investigation and remediation to prevent recurrence; (d) reasonable measures for continued processing in the event of confidentiality, integrity or availability of such personal data being compromised as a result of destruction or loss of access to personal data or otherwise, such as by way of data-backups; (e) for enabling the detection of unauthorised access, its investigation, remediation to prevent recurrence and continued processing in the event of such a compromise, retain such logs and personal data for a period of one year, unless compliance with any law for the time being in force requires otherwise; (f) appropriate provision in the contract entered into between such Data Fiduciary and such a Data Processor, wherever applicable, for taking reasonable security safeguards; and (g) appropriate technical and organisational measures to ensure effective observance of security safeguards. (2) In this rule, the expression “computer resource” shall have the same meaning as is assigned to it in Information Technology Act, 2000 (21 of 2000).