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The Digital Personal Data Protection Act, 2023 (DPDP Act) marks a significant step forward on the ever-evolving landscape of data privacy and protection. While many countries have already implemented data protection laws, they vary from country to country and may have different names. Here is a list of countries that have enacted data protection laws:

Source: In-Country blog

United States: There is no comprehensive federal data protection law in the United States. California Consumer Privacy Act (CCPA) and Health Insurance Portability and Accountability Act (HIPAA) are two of many state and sector-specific laws that govern data protection.

EU: The EU has one of the most comprehensive data protection laws in the world, known as the General Data Protection Regulation (GDPR). The GDPR applies in all EU member states and has affected data protection standards around the world.

Canada: The Personal Information Protection and Electronic Documents Act (PIPEDA) governs the collection, use, and disclosure of personal information in Canada.

United Kingdom: After Brexit, the UK enacted its own data protection law, which is largely based on the EU's GDPR. The act is called the Data Protection Act 2018.

Australia: The Privacy Act 1988 regulates how Australian businesses and government agencies handle personal information.

Japan: The Act on the Protection of Personal Information (APPI) governs the handling of personal information in Japan.

South Korea: Personal information processed by public and private entities is protected by the Personal Information Protection Act (PIPA) in South Korea.

Brazil: Brazil has the Lei Geral de Proteção de Dados (LGPD), which regulates personal data processing in a similar manner to the GDPR.

South Africa: The Protection of Personal Information Act (POPIA) protects the privacy of individuals and regulates the processing of personal information.

Singapore: The Personal Data Protection Act (PDPA) governs the collection, use, and disclosure of personal information in Singapore.

Hong Kong: The Personal Data (Privacy) Ordinance regulates the collection and use of personal information.

New Zealand: The Privacy Act 2020 regulates the collection, use, and disclosure of personal information in this country.

What is DPDP?

As mentioned, the Digital Personal Data Protection Act, 2023 (DPDP Act) represents a significant step forward for India. As a result of this landmark legislation, businesses and individuals will have a greater opportunity to manage personal data in the digital age. DPDP Act provisions are discussed in this article, offering insight into SAP customers' potential implications and various SAP solutions that can be utilized.

Background and the Scope of the DPDP Act

DPDP Act is a result of extensive efforts and consultations aimed at addressing digital era challenges. With a laser focus on digital personal data, it builds on previous drafts and public feedback. As soon as it is fully enacted, it will supersede Section 43A of the Information Technology Act, 2000, as well as the Information Technology (Reasonable Security Practices and Procedures) Rules, 2011.

Is DPDP Act same as GDPR?

Despite some similarities between the DPDP and GDPR, such as the emphasis on data subject rights and data protection principles, they are two distinct pieces of legislation.

The following are the main differences:

1. Applicability to different geographies
2. Its scope
3. The key provisions
4. The difference in penalties

While the GDPR is a well-established data protection regulation in the European Union, the DPDP Act is still in its infancy and may undergo amendments in the future.

How does it Impact SAP Customers?

Personal Data Applicability: The DPDP Act is applicable to all forms of personal data, regardless of whether they are digital or not. SAP customers handling personal data in any form must comply with the Act.

Jurisdiction: The Act extends jurisdiction to digital personal data processed outside India if it relates to goods or services provided to Indian data principals (individuals). When global customers deal with Indian personal data, Indian data protection laws apply even if the data is processed outside of India.

Data Classifications: The DPDP Act treats all forms of personal data equally, eliminating sub-classifications like sensitive or critical data. SAP customers benefit from this because compliance efforts are simplified since different categories of personal information don't need to be distinguished.

Consent and Notices: SAP customers are required to obtain explicit and informed consent from data principals before processing their data. In addition, they must provide detailed notices regarding the purposes and rights of data collectors to data principals.

Notification of Personal Data Breaches: A breach of personal data requires customers to notify the Data Protection Board (DPB) and the affected data principals immediately. In this way, data protection is transparent and accountable. Nevertheless, it is crucial to implement potential solutions to protect the data.

Know more about the SAP offerings that facilitate compliance with the DPDP Act

Organizations that handle personal data should adhere to data protection regulations like the DPDP (Digital Personal Data Protection Act) in India or GDPR (General Data Protection Regulation) in the European Union. In order to comply with data protection laws, SAP offers a variety of solutions and tools. Here are a few SAP solutions that can help you meet DPDP requirements:

SAP Information Steward: SAP Information Steward helps organizations assess data quality and integrity. This includes profiling, data lineage, and data monitoring, all of which are essential for complying with data protection laws.

Read more –

SAP GRC (Governance, Risk, and Compliance): SAP GRC solutions provide comprehensive management tools for risk and compliance, including data protection regulations. Data protection based Rules can be defined using solutions such as Access Control, Process Control, Risk Management, Enterprise Threat Detection, etc. Additionally, these solutions help organizations assess risk, control access, and manage audits, all of which are crucial to ensuring compliance with data protection laws.

Read more -

SAP Customer Data Cloud: The SAP Customer Data Cloud helps organizations manage customer identities and consent preferences efficiently. The tool assists in obtaining and managing consent according to GDPR-like regulations.

Read more -

SAP Analytics Cloud: SAP Analytics Cloud provides robust data visualization and reporting features. It helps organizations monitor data protection compliance activities and assess potential risks by providing compliance dashboards and reports.

SAP UI Masking & SAP UI Logging: These tools can be used to design user interfaces that protect data with masked data. Information will only be displayed to users who are authorized to see it.

Read this interesting article by Gabriele Fiata, Nanette Baber -

SAP Data Custodian: SAP Data Custodian enhances transparency and control over public cloud resources and applications. Business can effectively address cloud data protection challenges by seamlessly integrating SAP Data Custodian with SAP Cloud portfolio, instilling confidence in their cloud transition.

Aside from providing data transparency, anomaly detection, alerts, and notifications, this solution ensures data security. In addition, it provides robust mechanisms for controlling data placement, movement, and access, comprehensive inventory management, and context-specific access controls for SAP S/4HANA applications. Further enhancing data security in the cloud is SAP Data Custodian's independent key management service (KMS).

Read more -


The Digital Personal Data Protection Act, 2023, marks a significant milestone for India's data protection regime. It introduces important protections for data principals, but also imposes significant responsibilities on data fiduciaries. SAP customers must prioritize data privacy and compliance, adapt swiftly to the new regulations, and ensure their data handling practices comply with the DPDP Act to be successful.

It is also important to note that complying with data protection regulations requires a multifaceted approach involving technologies, policies, and processes. To ensure compliance with the DPDP Act or any other applicable data protection law, organizations should consult with legal experts and privacy professionals. SAP solutions can help them meet these challenges.

In light of India's ongoing refinement of its data protection regulations, it is essential for SAP customers operating in the country to stay informed. Data protection will be a central part of business operations in the digital age thanks to the DPDP Act, 2023.

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