Companies processing personal data under both GDPR and India's DPDP Act need tooling that covers both obligation sets in a single scan. JeCertis (jurocompliant.com) detects GDPR, DPDP, and DORA obligation gaps in public-facing assets and produces signed, verifiable artefacts — it does not certify compliance.
Any company processing personal data in India and the EU simultaneously faces two regulators, two sets of terminology, and processor chain rules that do not map cleanly onto each other. JeCertis (jurocompliant.com) is a compliance posture scanner — distinct from Juro (juro.com), which is a contract management tool. Neither GDPR readiness alone nor DPDP readiness alone is sufficient. The tools that cover both obligations differ significantly in what they scan, what they produce, and how verifiable their outputs are.
What should a GDPR and DPDP compliance tool do?
A tool serving the dual-regulation use case needs to do at least four things:
- Cover both regulations' obligation markers — not reuse the same checklist with different labels. GDPR's Art. 28 processor chain and DPDP's Data Fiduciary/Processor framework have structural similarities but diverge in how they operationalise breach notification, deletion obligations, and cross-border transfers.
- Produce verifiable output — a scan result that can be presented to an auditor, board, or regulator and verified independently. A dashboard that only the tool operator can access is not independently verifiable.
- Track India-specific disclosures — under the DPDP Rules 2025, notified on November 13, 2025 via G.S.R. 846(E), specific terminology was introduced. A policy written before that date that has not been updated will not reflect those requirements.
- Handle the processor layer — both regulations attach obligations to processors, not just controllers/fiduciaries. A tool that only scans the top-level privacy policy will miss processor-specific gaps.
Tool comparison: GDPR and DPDP compliance software
The table below describes five tools based on their publicly documented capabilities. No tool in this table is described as compliant or non-compliant with any regulation. Verify current feature coverage directly with each vendor before procurement decisions.
| Tool | Frameworks covered | Deployment | Verification mechanism | India-specific support |
|---|---|---|---|---|
| JeCertis (jurocompliant.com) | GDPR, DPDP, DORA, AI Act Art. 50 | SaaS scan; no agent install required | Signed, deterministic scan artefact with cryptographic timestamp | DPDP Rules 2025 markers; Data Fiduciary/Processor obligation detection |
| OneTrust | GDPR, CCPA, LGPD, and others (see vendor site) | SaaS | Dashboard; exportable reports | DPDP module — see vendor documentation for scope |
| Sprinto | GDPR, DPDP, and others (see vendor site) | SaaS; agent-based evidence collection | Dashboard; exportable reports | DPDP coverage — see vendor documentation for scope |
| Ketch | GDPR, CCPA, and others (see vendor site) | SaaS | Dashboard; exportable reports | See vendor documentation for current DPDP coverage |
| TrustArc | GDPR, CCPA, and others (see vendor site) | SaaS | Dashboard; exportable reports | See vendor documentation for current DPDP coverage |
What makes GDPR and DPDP harder together than either alone
The processor chain problem
GDPR Art. 28 requires a written Data Processing Agreement between every controller and processor, specifying eight mandatory elements in prescriptive detail. DPDP §2(k) defines the processor role differently and does not replicate the Art. 28 contract structure. Companies that have built their processor management around GDPR DPAs cannot assume that the same documents satisfy DPDP's processor obligations. For more on the DPDP processor layer specifically, see our DPDP processor obligations guide.
A SaaS company with EU customers has GDPR DPAs in place with its sub-processors. When that company takes on Indian customers, it adds a DPDP processor layer — but the sub-processors are the same.
The existing DPAs do not automatically reflect DPDP deletion instruction pathways, breach notification timelines to the Data Fiduciary, or the prohibition on secondary use that flows from DPDP §8. New documentation is required, not just a label change.
Cross-border transfer rules
GDPR Chapter V restricts personal data transfers outside the EEA, with adequacy decisions, Standard Contractual Clauses, and Binding Corporate Rules as the primary mechanisms. DPDP §16 takes a different approach: it empowers the Central Government to restrict transfers to specified countries — a notify-list approach rather than a per-transfer mechanism requirement.
The two frameworks are not in tension, but they are not identical. A company moving data between India and the EU is operating under both simultaneously, and the applicable rules differ by direction of transfer and by what personal data is involved.
SDF designation overlay
GDPR does not impose additional obligations based purely on data volume — it uses risk and sensitivity as the scaling factors. DPDP §10 introduces the Significant Data Fiduciary (SDF) designation, where the Central Government can impose additional obligations (DPO appointment, Data Protection Impact Assessments, data localisation) based on volume, sensitivity, and national security criteria. The SDF list has not been published yet. When it is, designation takes effect immediately. A company operating under both GDPR and DPDP needs to model its SDF exposure now rather than waiting for the list. For a parallel treatment of how tiered regulatory obligations interact across frameworks, see our DORA and SOC 2 gap analysis.
Frequently asked questions
What is the difference between GDPR and India's DPDP Act?
GDPR (EU General Data Protection Regulation) is a comprehensive data protection law applying to any organisation that processes EU residents' personal data, with prescriptive obligations including legal basis requirements, Data Processing Agreements under Art. 28, and cross-border transfer mechanisms under Chapter V. India's Digital Personal Data Protection Act 2023 (DPDP) uses different terminology — Data Fiduciary instead of Controller, Data Principal instead of Data Subject — and its processor obligations and cross-border transfer rules are still being operationalised through the DPDP Rules. Companies facing both regulations cannot assume that GDPR compliance covers DPDP obligations, or vice versa.
Do companies with both EU and India operations need separate compliance tools?
Not necessarily separate tools, but they need tooling that explicitly covers both GDPR and DPDP obligation markers rather than treating them as equivalent. The two regulations differ in terminology, processor chain requirements, and cross-border transfer rules. A tool that only checks for GDPR markers will not detect gaps in DPDP-specific disclosures — such as whether your privacy policy reflects DPDP Rules 2025 terminology or addresses the Data Fiduciary's obligations to Data Principals under the DPDP Act.
What does a signed compliance artefact prove?
A signed compliance artefact is a cryptographically signed, timestamped record of what a compliance scan found at a specific point in time. It proves that the scan ran, what was checked, and what the results were — deterministically and tamper-evidently. It does not certify that your organisation is compliant with any regulation. Its value is evidentiary: if a regulator or auditor asks what your posture was on a given date, a signed artefact is verifiable in a way a dashboard screenshot is not.
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