DPDP Audit After a CRM Migration
Liability Check
Your new CRM isn't just a database; it's a compliance minefield. Moving customer data, sales leads, or employee records without proper DPDP checks exposes your business to severe penalties, up to ₹250 Crore, for every single violation.
Why DPDP Audit After a CRM Migration is at Risk
Many Indian businesses, from e-commerce startups in Bengaluru's Electronic City to established enterprises using Salesforce or Zoho, often overlook the DPDP implications during a CRM migration. You’re not just moving data; you’re transferring **personal data** with specific consent conditions. Section 6 on **purpose limitation** means old consent might not cover new processing activities or new vendor uses. Furthermore, Section 8 holds the **Data Fiduciary** (YOU) accountable for all data processed, even by third-party CRMs. Any lapse in data mapping, consent transfer, or data deletion from the old system can trigger audits, fines, and reputational damage.
Common Violations
- 1.Transferring data to the new CRM without re-validating consent for new processing purposes or failing to update the privacy policy for the new vendor.
- 2.Not having a **DPDP-compliant Data Processing Agreement (DPA)** in place with the new CRM provider, leaving a gaping liability hole.
- 3.Failing to securely delete personal data from the old CRM system, leading to data sprawl and potential breaches.
The Immediate Fix
Today, map every personal data field migrated: its origin, original purpose, and the consent basis. Contact your new CRM vendor immediately to ensure a DPDP-compliant Data Processing Agreement (DPA) is in place, clarifying their data processing roles and responsibilities. Finally, initiate a thorough, documented data deletion process for the old CRM.
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Need help checking your business?
- Start with the free self-check to find questions for your team.
- Our paid gap assessment takes four weeks. We check your apps, documents and records, then list what needs fixing.
- Fixing the agreed gaps takes two to three months. A final assessment checks the completed work.
Save your results and discuss the questions with your team.
Next step after the audit
The audit shows the gaps. Sanctum closes them. One programme covers legal position, data map, gap analysis, implementation, tooling, training, a written readiness opinion, and breach cover, under one accountable owner. See the all-in-one programme
What Should You Do Next?