GDPR might be the world’s most famous privacy law, but the DPDPA is the one that actually governs your Indian operations. We’re putting them side-by-side to show you why your “Global Privacy Policy” might leave you legally exposed to India’s unique rules on consent and language.

For many global companies, the GDPR has been the ultimate playbook for data privacy. You’ve likely spent years mapping data, drafting complex policies, and training teams to meet European standards. However, as the Digital Personal Data Protection Act (DPDPA) rolls out in India, a new challenge is emerging: assuming that GDPR-compliant means DPDPA-ready is a dangerous mistake.

While both laws share the same heart, protecting individual privacy, the DPDPA introduces specific local requirements that simply don’t exist in the European model. From the mandatory use of 22 regional languages to the absence of the broad Legitimate Interest loophole, the DPDPA is designed for India’s unique digital ecosystem. In this blog series, we are going to break down these differences part by part, starting with the fundamental shift in how we define data and legal permission.

If you’ve already built your infrastructure to meet GDPR standards, you’ve done 80% of the work. However, the DPDPA isn’t a copy-paste of the GDPR; it has a few specific Indian nuances that require you to tweak your back end systems. Following our simplified style, here are the 4 key infrastructure changes you need to make to transition from GDPR to DPDPA.

1. Language Localization at the Database Level

Under GDPR, you likely have a standardized privacy notice in English (and perhaps a few European languages). The DPDPA is much more demanding about linguistic accessibility.

• You must give users the option to view their notice and manage consent in English or any of the 22 regional languages listed in the Indian Constitution.

• You need a Multilingual Consent UI that isn’t just a translation on the front end. Your database needs to log which language version of the notice the user agreed to, ensuring that if a dispute arises, you can prove they saw the notice in their preferred language.

2. Integrating with the “Consent Manager” Ecosystem

The GDPR assumes you (the Controller) manage the relationship with the user directly. The DPDPA introduces a middleman called a Consent Manager.

• An Indian user can choose to manage all their consents via a third-party app (a Consent Manager) rather than on your website.

• You need to build Interoperable APIs that allow these registered Consent Managers to talk to your system. When a user changes a preference on a third-party app, your back-end must automatically update in real-time.

3. Redefining the Age of Consent Workflows

In Europe, the age of digital consent is usually 16 (and sometimes as low as 13). In India, the DPDPA sets a hard line at 18 years old.

• Anyone under 18 is a child under the DPDPA. You are strictly prohibited from tracking, behavioral monitoring, or targeted advertising for these users.

• You need to update your Age-Gating Logic. If a user is flagged as under 18 in India, your system must automatically kill any tracking pixels, ad-tech cookies, or profiling scripts that would normally run for a 16 or 17-year-old in Europe.

4. Stricter “Legitimate Use” Logic

GDPR has a broad Legitimate Interest category that acts as a safety net for things like fraud detection or internal analytics. The DPDPA’s Certain Legitimate Uses are much narrower.

• You can no longer rely on a vague business interest to process data without consent in India.

• You need to audit your Data Processing Logs. If you have automated workflows running on Legitimate Interest in the EU, you must either find a specific DPDPA exemption (like an emergency or legal duty) or update your UI to collect Explicit Consent before that data ever hits your server.

While the GDPR is often called the gold standard of privacy, comparing its controls with the DPDPA reveals that India’s law isn’t just a copy,  it’s a specialized version designed for a mobile first, multilingual population

1. The Legal Basis Control: Flexibility vs. Focus

The biggest shock for GDPR-compliant firms is how many legal doors the DPDPA closes.

• GDPR offers six lawful bases for processing, including the very popular Legitimate Interest. This allows companies to process data for things like internal analytics or marketing without asking every single time.

• DPDPA is almost entirely Consent-Centric. It replaces the broad Legitimate Interest with a much narrower list of Certain Legitimate Uses (like medical emergencies or employment).

• If you are currently using Legitimate Interest in Europe, you will likely need to build a new Consent Workflow for India.

2. The “Notice” Control: Transparency vs. Accessibility

Both laws demand transparency, but India adds a heavy operational requirement for language.

• GDPR requires notices to be in clear and plain language. Usually, one or two languages per region are enough.

• DPDPA mandates that a notice must be accessible in English or any of the 22 regional languages listed in the Indian Constitution.

• You need a Dynamic UI Control that can toggle between 22 languages, ensuring every Indian user can read your privacy terms in their native tongue.

3. The “Child Safety” Control: 16 vs. 18

The DPDPA sets one of the highest bars in the world for protecting younger users.

• GDPR defines a child as someone under 16 (though some EU countries lower this to 13). It allows for reasonable efforts to verify parental consent.

• DPDPA sets the age of a child under 18. It strictly prohibits behavioral tracking or targeted advertising for anyone in this age group.

• Your Ad-Tech and Tracking Controls must be updated. A 17 year old who is tracked as an adult in London must be treated with child-level privacy in Mumbai.

4. The “Breach Notification” Control: Risk vs. Absolute Duty

This is where the DPDPA becomes much stricter on your security team.

• Under GDPR, you only have to report a breach if it is likely to result in a risk to the person.

• Under DPDPA, you must report every personal data breach to the Data Protection Board and the affected user, regardless of the risk level.

• Your Incident Response Plan needs to be re-tuned. In India, there is no low-risk exception; if data is leaked, you must report it.

5. The “Consent Manager” Control: Unique to India

This is a control that simply does not exist in the GDPR.

• Under GDPR, the relationship is direct between the company and the user.

• DPDPA introduces the Consent Manager, a registered platform that manages a user’s permissions across multiple companies in one place.

• Your back-end must include Interoperable APIs that allow these third-party managers to pull or revoke consent on behalf of your users.

The Bridge: Why ARC is Your DPDPA Shortcut

Transitioning from GDPR to DPDPA isn’t just about rewriting your policies; it’s about upgrading your technology. This is where ARC comes in. If you are already managing a complex GDPR framework, you don’t need a new set of manual spreadsheets, you need an AI-powered orchestration layer. ARC is specifically designed to bridge the gap between global standards and Indian law.

• Automated Multilingual Notices: ARC automatically manages your privacy notices across all 22 regional languages, ensuring you meet India’s accessibility rules without hiring a translation team.

• Consent Manager Integration: ARC’s zero-code APIs allow you to plug directly into India’s emerging Consent Manager ecosystem, giving your users a seamless way to manage their permissions.

With ARC, you can turn your GDPR foundation into a DPDPA-compliant powerhouse in a fraction of the time.

Book your Personalized ARC Demo

Conclusion: Beyond the Foundation

Ultimately, your GDPR journey has given you a head start, but it is not the finish line. In the new global economy, leadership is defined by the ability to adapt. As we’ve seen, the DPDPA is a reminder that every market has its own heartbeat, and India’s law is uniquely crafted for a digital-first, multilingual population that values explicit consent and parental oversight.

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• Learn DPDPA: https://dpdpaedu.org

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