With the passage of the Digital Personal Data Protection Act (DPDPA) in 2023, India signaled its arrival as a global leader in data privacy and governance. The law establishes a modern, consent-driven framework for personal-data protection, one designed to safeguard the digital rights of India’s 1.4 billion citizens while fostering trust in a rapidly expanding digital economy.
But with this evolution comes new responsibility. For organizations operating in or serving India, compliance isn’t just about policy; it’s about architecture. Ensuring personal data remains within India’s borders, under local governance and control, requires technology that enforces both visibility and jurisdictional integrity.
That’s where AppGate’s direct-routed Zero Trust Network Access (ZTNA) offers a strategic advantage.
Understanding the Digital Personal Data Protection Act
The DPDPA is built on several key principles:
- Consent-based processing: Personal data can only be collected and used for legitimate, consented purposes.
- Defined responsibilities: Organizations handling data (“data fiduciaries”) and their processors (“data processors”) must implement strong security and accountability measures.
- Individual rights: Data principals (individuals) have the right to access, correct, and request erasure of their data.
- Cross-border oversight: The Indian government retains authority to specify countries or regions where personal data may be transferred.
While the DPDPA allows for some international data flows, it places the burden of compliance squarely on organizations to prove that data remains protected and traceable wherever it travels.
Cross-Border Data Transfers and Sovereignty
The DPDPA’s most impactful clause concerns cross-border data transfers.
Unlike older sector-specific regulations, the DPDPA establishes a central rule: personal data originating in India should not leave its jurisdiction unless explicitly permitted.
For many global enterprises and cloud-dependent services, this presents a new challenge, ensuring that data paths, session metadata, and identity information don’t traverse or terminate outside India.
Cloud-routed ZTNA models, which rely on vendor-controlled points of presence (PoPs) hosted across multiple regions, can unintentionally violate this mandate by routing traffic through servers beyond Indian borders.
Even if data remains encrypted, such routing may still constitute a transfer under the law’s interpretation.
How AppGate ZTNA Enables DPDPA Compliance
AppGate’s direct-routed architecture ensures full control over where data flows and where it stays.
- Direct Path, No Vendor PoPs
User sessions connect directly from device to authorized resource without passing through vendor-owned infrastructure. This prevents unintended cross-border routing and ensures personal data stays within India’s network boundaries. - Customer-Controlled Deployment
Organizations can deploy AppGate controllers and gateways within India—on-premises, in private data centers, or through India-based cloud providers—maintaining complete jurisdictional control. - Context-Aware, Least-Privilege Access
Every connection is dynamically authorized based on user identity, device posture, and contextual risk, limiting access to only the necessary data and systems. This aligns with DPDPA’s principle of responsible and minimal data processing. - Proven Accountability and Auditability
AppGate provides detailed access logs and policy enforcement records that help demonstrate compliance to auditors and regulators, supporting DPDPA’s emphasis on transparency and accountability. - Secure Processing and Encryption
By ensuring encryption in transit and at rest, AppGate safeguards personal data from interception or misuse, meeting DPDPA’s requirement for “reasonable security safeguards.”
Empowering Indian Enterprises and Global Organizations
India’s DPDPA reflects a broader shift toward data sovereignty and digital independence. For Indian enterprises, it ensures that personal data—from financial records to healthcare information—remains within national oversight. For multinational organizations, it creates the need for adaptable architectures that can enforce local compliance without fragmenting global operations.
AppGate’s direct-routed ZTNA bridges both worlds. It lets global companies meet Indian data-protection obligations while maintaining the agility and scalability of modern cloud operations, all without sacrificing performance or user experience.
Conclusion
India’s Digital Personal Data Protection Act represents a major step toward secure, transparent, and accountable digital governance. As organizations adapt to these new requirements, architecture will define compliance success.
AppGate’s direct-routed ZTNA helps enterprises meet DPDPA expectations by keeping data where it belongs—within India’s borders, under your control, and always protected.
Ready to localize your Zero Trust strategy for India’s DPDPA? Schedule a consultation with our compliance experts today.