Dhristhi DPDP
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Control-Test Harness

Automated Obligation-to-Evidence Test Harness & Compliance Workpapers

Engineered By: Dhristhi Privacy Engineering
Edition: Enterprise Edition
Release: 2026 Release

Product Overview & Key Capabilities

An automated compliance verification and audit workpaper harness that continuously tests enterprise technical systems against the 54 canonical DPDP operational controls, executing positive/negative test fixtures and packaging cryptographic evidence bundles for internal and statutory SDF audits.

Core Enterprise Capabilities
54 pre-built automated test suites evaluating compliance across all canonical DPDP operational controls (OBL-01 to OBL-54).
Negative test fixture injection detecting unhashed notices, stale consent tokens, and unverified parental consent flows.
Objective test outcome recording (PASS, FAIL, INCOMPLETE) strictly separated from auditor review judgment.
One-click packaging of tamper-evident SHA-256 evidence bundles for Board and statutory independent data audits.
Deliverable & Core Artifact

Automated control test execution harness, structured audit review workpapers, and portable evidence packaging format.

Target Roles & Operational Impact

Target Persona & Role Decision Authority Operational Value & Impact
Control Owner & Lead Engineer Implementation Lead Document failing execution paths, remediation diffs, and exact retest commits.
Independent Assurance Auditor Acceptance Veto Evaluate whether test populations, sampling methodology, and raw artifacts substantiate compliance conclusions.
DPO & Audit Sponsor Executive Sign-Off Distinguish voluntary internal control readiness from statutory SDF independent data audits.

Data Schema & Architecture Interface Contracts

The following data schemas and interface contracts define the structured payloads and integration endpoints of this product:

workpaper
workpaper_id; canonical_obligation_id (OBL-01..54); applicability_decision; control_test_id; environment_digest; population_size; sample_selection_method; expected_vs_actual; test_result (PASS, FAIL, NOT_RUN, INCOMPLETE); evidence_ids; residual_risk; tester; reviewer
retest_history
baseline_failure_id; correction_version; retest_result; missing_external_evidence; review_scope; reviewer_action (ACCEPT_IN_SCOPE, RESTRICT, RETEST, UNVERIFIED); manifest_digest

Operational Workflow & Product Invariants

Execution Workflow Procedure

  1. Select target operational control (OBL-01 to OBL-54) and instantiate corresponding review workpaper.
  2. Define sample population, testing environment, test data fixtures, and expected normative behavior.
  3. Execute positive and negative test cases; capture raw log traces, configuration hashes, and contract receipts.
  4. Record objective results (PASS, FAIL, INCOMPLETE); document any unobserved failure modes or residual risks.
  5. Independent reviewer examines evidence and assigns sign-off status (ACCEPT_IN_SCOPE, RESTRICT, or RETEST).

Mandatory Product Invariants

  • P04-R01: Record objective test result (PASS, FAIL, NOT_RUN, INCOMPLETE) strictly separately from reviewer judgment (ACCEPT_IN_SCOPE, RESTRICT, RETEST, UNVERIFIED).
  • P04-R02: Missing required evidence must produce INCOMPLETE; never convert absent processor receipts to PASS because internal tests succeeded.
  • P04-R03: Use explicit declared fixture inventories. Mathematical sample formulas do not replace verified sample extractions.
  • P04-R04: Independent auditor appointment and SDF audit standards remain external legal requirements; software cannot guarantee clean audit certificates.

Operational Boundaries & Architecture Assumptions

  • • No automated legal certification or guarantee of zero regulatory penalties.
  • • No automated production environment penetration testing or vulnerability exploitation.
  • • No replacement for formally appointed independent data auditors under Section 10(2)(b).

Built-in Quality Verification & Compliance Test Harness

P04-A01-TEST Verified
Negative Fixture Injection

Verify that test fixtures containing invalid consent tokens or unhashed notices correctly trigger FAIL and INCOMPLETE states.

P04-A02-TEST Verified
Audit Trail Integrity

Validate that modifying test results creates a new versioned history log without overwriting baseline failure records.

P04-A03-TEST Verified
Evidence Bundle Packaging

Verify that all referenced log files, configs, and specimen artifacts are packaged into portable SHA-256 bound bundles.

Statutory Grounding & Regulatory Crosswalk

7 Enforced Provisions

The following primary Act sections and subordinate Rule provisions establish the direct legal grounding, mandatory statutory constraints, and operational compliance duties enforced by this product:

Direct Citations: Section 8Section 10Section 15Section 28Section 33Rule 6Rule 13
ACT-8 s.8
Tranche 3 (13 May 2027)

Section 8

Actor: Data Fiduciary
Trigger: Processing by it or its processor

Responsibility despite agreements/principal default; valid processor contract; conditional data accuracy; safeguards; breach intimation; erasure; contact and grievance mechanism.

Product Invariant: Receipt is not proof of erasure; fulfilment of one test is not statutory assurance.
Exception: s8(7) lawful-retention exception; s17 preserves s8(1),(5) under subsection (1).
Gazette Verified View Provision (s.8)
ACT-10 s.10
Tranche 3 (13 May 2027)

Section 10

Actor: Central Government; notified SDF
Trigger: Notification of fiduciary or class following relevant-factor assessment

India-based individual DPO responsible to governing body; independent auditor; periodic DPIA/audit and prescribed measures.

Product Invariant: Voluntary readiness is not a legal designation; independence is not an express firm-wide ban here.
Exception: Not automatic from scale/sensitivity; designation and effective timing matter.
Gazette Verified View Provision (s.10)
ACT-15 s.15
Tranche 3 (13 May 2027)

Section 15

Actor: Data Principal
Trigger: Exercise of rights and provision of data

Comply with laws; no impersonation, suppression of specified material information, false/frivolous complaint; authentic correction/erasure information.

Product Invariant: Do not punish legitimate withdrawal or make legal rights conditional on unrelated duties.
Exception: Does not remove fiduciary responsibility: s8(1).
Gazette Verified View Provision (s.15)
ACT-28 s.28
Tranche 3 (13 May 2027)

Section 28

Actor: Board
Trigger: Receipt of s27 material and sufficient grounds for inquiry

Independent digital design; recorded reasons/natural justice; listed civil-court powers; hearing and completion route to s33.

Product Invariant: Do not present inquiry as automatic penalty.
Exception: No premises-access prevention or equipment custody adversely affecting day-to-day functioning; insufficient grounds close; frivolous complaints costs/warning.
Gazette Verified View Provision (s.28)
ACT-33 s.33
Tranche 3 (13 May 2027)

Section 33

Actor: Board; person found in significant breach
Trigger: Conclusion of inquiry, significant breach and hearing

May impose scheduled penalty; seven statutory factors.

Product Invariant: No expected-loss formula from fixture pass rate; aggregate exposure requires separate legal analysis.
Exception: Discretionary maximum, no fixed multiplier from mitigation.
Gazette Verified View Provision (s.33)
RULE-6 r.6
Tranche 3 (13 May 2027)

Rule 6

Actor: Data Fiduciary; processors by contractual propagation
Trigger: Protection of possessed/controlled data

Minimum security, access, visibility, continuity/backup, one-year security data/log retention, contract safeguards, organisational/technical measures.

Product Invariant: No required algorithm or proof that one passed test satisfies s8(5).
Exception: r6(1)(e): unless compliance with law requires otherwise.
Gazette Verified View Provision (r.6)
RULE-13 r.13
Tranche 3 (13 May 2027)

Rule 13

Actor: Notified SDF; assessment/audit person; Central Government
Trigger: Designation; algorithms; Government data specification

DPIA and audit once each twelve-month period from notification; significant observations report by assessor/auditor; algorithmic technical-measure diligence; specified data/traffic not abroad.

Product Invariant: No KS, AUC, fairness-code or API threshold supplied here; correct Departments in (5).
Exception: Data restriction requires specification on committee recommendation; no general all-data localisation.
Gazette Verified View Provision (r.13)

Target Systems Topology (SYS-001..014)

View Complete Architecture Topology →
SYS-001 System Spec →
Customer App & Web Portal

Public client boundary & untrusted intake surface for notices and consent capture

SYS-002 System Spec →
Core Lending Monolith & Transaction Store

Domestic production database and primary system of record for loan servicing

SYS-004 System Spec →
Enterprise Cloud Data Warehouse

Purpose-partitioned analytical warehouse staging operational reporting

SYS-010 System Spec →
Consent Ledger & Policy Decision Point

Immutable consent event store and Policy Decision Point issuing authority tokens

SYS-012 System Spec →
SIEM & Security Telemetry Store

Security log repository preserving tamper-evident dual-clock audit trails

SYS-014 System Spec →
Restore Quarantine & Sandbox Store

Isolated test environment ensuring recovered backups pass tombstone replay

Enterprise Evidence Artifacts Vault

The following verifiable artifacts and test workpapers are generated by this product:
CONTROL_TEST_HARNESS_WORKPAPERS.md
Automated_Test_Runner_Manifest.json
Sample_Selection_Workpaper_Template.xlsx
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