SCENARIO H04 · PROCESSORS & EVIDENCE
An applicant-tracking vendor’s contract no longer matches how records are hosted. What should change?
IN PLAIN ENGLISH
Why you are seeing this step
This field note uses one realistic decision to separate the official source, an editorial interpretation, a practical option, evidence to keep, and any uncertainty that still depends on your facts.
Educational only, not legal advice. Source status is dated 13 May 2027; inspect the official links below before relying on it.
BEST NEXT STEP
Fix the valid contract and safeguard terms, then reconcile the processor inventory.
Bring the legal instrument and the operating model back into alignment without claiming the Act expressly mandates a particular inventory format.
WHY THE OTHER INSTINCTS MISS
Fix the valid contract and safeguard terms, then reconcile the processor inventory.
Correct. Contract and safeguards are legal anchors; the inventory is implementation evidence showing the real arrangement.
Update only the internal inventory.
An accurate inventory does not cure a contract that fails to reflect the processor engagement.
Update only the contract and avoid checking operations.
Paper terms that are not matched to actual hosting and access remain weak evidence.
BUILD THIS EVIDENCE
Corrected contract, safeguard schedule, hosting/access map and review sign-off.
This artefact supports review. It does not certify compliance or replace advice on your facts.
- Guidance type
- legal requirement
- Pinpoint
- Act s. 8(1)–(2), 8(5); Rule 6(1)(f); G.S.R. 843(E) and 846(E)
- Reviewed
- 2026-08-30
- Change note
- Status and pinpoint reviewed against the official Act, final Rules, commencement notification and corrigendum for this educational website.
OFFICIAL SOURCE TRAIL
Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023) ↗
Definitions and specified machinery provisions are operative; most substantive duties and rights are notified for later commencement. Check each scenario's status record.
Act s. 1(2); provision-specific section pinpointsDigital Personal Data Protection Rules, 2025 (G.S.R. 846(E)) ↗
Final Rules with phased commencement. Scenario pinpoints identify the particular Rule being taught.
Rule 1(2)–(4), read with the corrigendumDPDP Act commencement notification G.S.R. 843(E) ↗
Appoints immediate, one-year and eighteen-month commencement cohorts for the Act.
G.S.R. 843(E), clauses (a)–(c)