By Vijender Yadav, CEO & Co-founder, Accops
Data breaches continue to rise globally at an alarming rate. In 2025 alone, major incidents exposed hundreds of millions of records, with one set of leaked credentials containing over 16 billion records from leading services. Closer to home, India’s digital economy faces mounting pressure as the Digital Personal Data Protection (DPDP) Act, 2023, becomes fully operational through the DPDP Rules notified in late 2025. The fine can go up to ₹250 crore for each violation, alongside reputational harm and operational fallout.
In this context, the role of enterprise access, including role-based access control (RBAC), the concept of least privilege (PoLP), multi-factor authentication (MFA), encryption, and logging, is at the center of compliance conversations. Lack of proper controls enables unauthorized access to personal data, making access a breach mechanism. For CIOs, this is no longer a choice but the first line of defense.
DPDP Act Essentials
The DPDP Act applies to all organizations that process the digital personal data of Indian residents, irrespective of geography and company size. The primary obligations are consent-based processing with simple withdrawal, data minimization, accuracy, strong security safeguards, and individual rights of access, correction, and deletion (usually within 90 days). Significant Data Fiduciaries are subject to additional scrutiny, including data protection impact assessments (DPIA).
The rules, notified in 2025, bring these principles into effect with a series of timelines commencing from November 2025. The immediate priorities are establishing governance and the complete operational obligations of the Act, including detailed notices, breach reporting within 72 hours to the Data Protection Board and CERT-In, and restrictions on cross-border transfers. They are expected to come into effect in 12-18 months, and enforcement momentum will pick up pace in 2026.
Why Enterprise Access Is the Critical Link
The security stack has traditionally broken down at the point of data rendering or exfiltration. Firewalls and encryption protect the data in transit and at rest, but once the data is rendered on a screen, the risk of data breaches from smartphone cameras, screenshots, or unauthorized sharing occurs outside of the security stack’s ability to protect it. Network-level blocks only go so far as they are perimeter-based and cannot enforce policy after data is rendered.
Poor enterprise access practices amplify this risk. Over-provisioned user accounts, inconsistent multi-factor authentication, poor logging, and the absence of contextual checks make it easy for insider threats, credential compromise, and supply chain breaches to succeed. Under DPDP, accountability also extends to processors, so third-party CRM or cloud access must meet the same security standards. In industries such as manufacturing or real estate, where customer information in CRM systems includes addresses, financial information, or preferences, weaker access controls can result in misuse or breaches that require mandatory reporting and fines.
Technical Priorities CIOs Must Address First
CIOs must start with these essential patches to establish a resilient foundation:
Data Classification and Inventory Mapping – Develop a dynamic inventory of personal data stored in on-premises, cloud, and third-party systems. Categorize by sensitivity, use, retention, and ownership. This underpins minimization and use limitation.
RBAC Overhaul with Zero-Trust Principles – Shift from trust by implication to trust by verification. Implement least-privilege access to ensure users view only required apps and data. Add device posture with device binding, location, time, watermarking and behavior analysis to deny suspicious access.
Automated Provisioning/De-Provisioning and Audit Trails – Implement identity infrastructure for just-in-time access and automated de-Provisioning based on role changes. Record fine-grained, immutable logs (user, device, resource, date/time) for breach analysis and annual retention.
MFA and Encryption Enforcement – Enforce MFA (biometric or passwordless methods) on all access to personal data. Ensure encryption at rest and in transit with centralized controls to prohibit local storage on devices.
Visual and Exfiltration Controls – Enable dynamic, user-level watermarks (injecting username, IP address, timestamp) for forensic analysis. Prohibit unauthorized screen capture, sharing, or download activity during sensitive sessions, while permitting approved business processes.
Centralized Delivery and Containment – Virtualize applications and desktops from datacenter-hosted platforms to keep data on servers rather than on endpoints. Apply gateway-based policies for consistent protection across VDI and remote environments. This approach extends security beyond access control to include control of the execution environment itself, achieved by consolidating desktops and endpoints into centrally managed virtual workspaces.
By following these best practices, blind spots inherent in legacy architectures can be eliminated, where multiple tools introduce complexity and risk.
Actionable Roadmap for the Next 18 Months
Begin immediately by appointing a DPO (required for Significant Data Fiduciaries), establishing a cross-functional team, and identifying data flows, and engaging a CERT-In empaneled auditor to assess current systems and identify gaps against DPDP Act guidelines.
By 12 months, revamp consent infrastructure (simplified, multilingual notices; opt-out simplified) and implement consent management, where applicable. At 18 months, implement complete RBAC, perform DPIAs if required, test breach response playbooks, and implement rights request and audit automation.
For Indian manufacturing or property companies, first audit CRM access (verify that sales teams cannot export customer data without safeguards) and model a breach exercise to test 72-hour notification preparedness.
Strategic Advantages and Final To-Do List
Enterprise access with high security standards instills trust, which is a powerful differentiator in the privacy-conscious Indian market. It facilitates safe AI application, underpins data-informed business decisions, and shortens breach analysis time with improved forensics.
CIO Checklist:
Assign DPO and start personal data mapping
Set up contextual zero-trust RBAC
Roll out MFA, logging, and watermarking/exfiltration prevention
Unify data residency through virtualization
Test breach response and automate rights processing
Assess vendor contracts for compliance
Educate staff and review quarterly
With 2026 enforcement deadlines approaching, these improvements will put organizations on the path to preparedness, not just compliance, in a trust-first digital economy.