Naavi/FDPPI has been working on DPDPA Compliance for different sectors including Banks.
In this process of developing DGPSI-Banks, it has been recognized that Indian Banks operate with a vide network of physical branches where Branch Managers and their employees interact with the customers starting from new account opening, to conducting KYC, processing loan applications etc. These operations are autonomous operations under the policy guidelines of their head offices which itself works under the RBI guidelines.
RBI guidelines of course are sectoral guidelines within the legal framework such as the DPDPA.
In this context, DGPSI which is the gold standard for DPDPA Compliance has carved out a “DGPSI-Banks” as a framework for Bank level compliance of DPDPA. Additionally, a separate simplified framework titled “DGPSI-Bank Branch” is being unveiled.
The purpose of this framework is to assist an autonomous Bank Branch to be compliant with DPDPA as a “Branch Level Significant Data Fiduciary”.
Under this scheme, DPDPA working through RBI and the HO will be the compliance guide. The Branch Manager is the “Branch DPO” (or any other name that may be ideally associated to the role) who is accountable for compliance of DPDPA along with the HO instructions, in compliance with RBI master directions and DPDPA.
Watch out for more information on this as we go ahead.
Naavi
