Voluntary Undertaking

Under the DPDP Act, a Voluntary Undertaking is a commitment that an organization may provide to the Data Protection Board of India to undertake specific actions related to compliance, remediation, or the addressing of identified concerns.

A voluntary undertaking allows organizations to proactively commit to corrective measures, such as improving privacy practices, implementing safeguards, addressing gaps, or taking steps to prevent future non-compliance. It reflects an approach in which organizations can work toward resolution by demonstrating accountability and a willingness to improve their data protection practices.

Organizations providing a voluntary undertaking must ensure that the commitments made are implemented effectively. Failure to comply with the terms of an accepted undertaking may result in further action as applicable under the DPDP framework.

In practice, gaps emerge when:

• Organizations do not have a structured remediation process.
• Compliance commitments are not tracked after submission.
• Corrective actions lack ownership or timelines.
• Evidence of completed actions is not maintained.
• Privacy gaps are addressed only after regulatory attention.

Organizations address these challenges by establishing compliance workflows, assigning accountability, tracking remediation activities, maintaining evidence, and continuously monitoring privacy controls. Within Privy, capabilities such as compliance workflows, risk management, evidence tracking, and governance reporting help organizations manage privacy commitments effectively.