DPO vs CISO: Where Security Ends and Privacy Begins

With the Digital Personal Data Protection (DPDP) rules out in 2025, one of the post imperative questions that is becoming quite common among companies:

Can the Chief Information Security Officer (CISO) also serve as the Data Protection Officer (DPO)? On the surface, it may seem reasonable to merge them after all, both roles deal with “data protection.” But if you take a deeper look at statutory responsibilities, independence requirements, and governance models, you will see why “DPO vs CISO” is not a matter of seniority but of fundamentally different mandates.

As organizations transition toward DPDP governance, it becomes critical to understand the clear separation of duties along with how DPDP compliance platforms like Privy enable DPOs to operationalize compliance at scale.

In this article, we will discuss the roles and responsibilities of DPO vs CISO , and how each contributes to the DPDP governance, and how Privy can enable DPOs to perform their duties effectively.

CISO: The Guardian of Cybersecurity

Some of the responsibilities of a CISO include cyber risk management, vulnerability testing and patching, incident breach mitigation, security governance and policies, technical compliance (ISO 27001, SOC II), and employee cybersecurity training.

Also Read: How ISO 27701 and GDPR Shape Privacy Governance in India

The primary role of the CISO is to ensure the confidentiality, availability, and integrity of the systems. This role is primarily very defensive, operational, and technical in nature.

DPO: The Guardian of Data Privacy

The role of the Data Protection Officer (DPO) as per the DPDP rules under section 10(2)(a), for Significant Data Fiduciaries (SDFs), is very different from that of a CISO. These roles not just include overseeing the compliance with the DPDP rules, but also conducting and reviewing DPIAs, managing breach under section 8(6), reporting directly to the Data Protection Board (DPB), ensuring lawful processing based on consent requirements and notices, facilitating Data Principal rights (access, correction, erasure, etc) and serving as the statutory point of contact for grievances.

This makes the DPO the privacy governance anchor with its mandate deep-rooted in ethics, law, and user rights, and not just technical defence. This is the major difference in the roles and responsibilities of CISO vs DPO.

Also Read: The DPDP Compliance Checklist (2025): Step-by-Step Guide for Indian Businesses

CISO vs DPO: Why One Person Should Not Do Both

While both roles overlap in areas like policy and awareness, they diverge sharply across:

How Privy by IDfy Enables DPOs Under the DPDPA

The responsibility of a DPO is highly documentation-driven, continuous, and broad. The ecosystem of Privy, including Privy Consent Shield, Privy Consent Governance Platform (CGP), Cookies Manager, and Inspect AI, is all designed to operationalise the DPDP compliance governance, give DPOs true control and visibility, and automate compliance.

1. Consent Governance Platform (CGP)

   The critical gap left by the traditional consent managers is filled by Privy’s CGP. It equips them with:

   • Dynamic Consent Configuration & Lifecycle Management: Allowing enterprises to revoke, give, audit, and re-consent actions for every purpose.

   • RoPA Automation: DPOs usually struggle to maintain enterprise-wide Records of Processing Activities. CGP of Privy automated RoPA with a complete mapping of PII, purposes, processors, and business processes.

   • Dashboards for DPOs: CGP comes with enterprise-level analytics on acceptance, consent issuance, withdrawals, and audits, helping the DPOs with real-time insight.

   • Multilingual Compliance (22 Indian Languages): Mandated by the DPDPA, CGP’s translation/transliteration engine ensures compliant notices across India’s linguistic diversity.

   • Sectoral Regulation Mapping: CGP maps sectoral rules (RBI/SEBI/IRDAI) to consent workflows, something global competitors lack.

   • Data Processor Governance: DPOs have full visibility on all the processors and the associated personal data flow, which eliminates the blind spots typically jeopardising compliance.

2. Consent Shield

   To prove compliance, DPOs must show tamper-proof consent artefacts. Privy’s consent shield provides the same:

   • SHA-256 Hashing with Salting: Ensuring integrity of consent artefacts for audit trails.

   • Digital Signatures: Enabling cryptographic verification of consent evidence.

   • Versioned Object Storage: Preserving a complete history of consent changes, very critical for DPDPA verification requirements.

   These features give DPOs indisputable, regulator-ready proof of compliance.

   Also Read: Top 5 Consent Management Platforms in India 2025

3. Inspect AI

   Inspect AI solves the biggest operational challenge for DPOs. Assessing every digital journey for DPDP compliance before and after go-live. The offerings of InspectAI are:

   • Automated Privacy Gap Assessments: AI models trained exclusively for DPDP compliance analyze data fields, forms, notices, privacy policies, and T&Cs .

   • Automated PII Identification & Purpose Mapping: The platform identifies PII fields, classifies them as sensitive/non-sensitive, and maps them to processing purposes.

   • RoPA Automation: Outputs integrate with CGP for unified RoPA generation.

   • Compliance Scoring: Every digital journey receives a DPDP compliance score for prioritization.

   • Pre-Go-Live Compliance Checks: Ensures no journey goes live before meeting DPDP requirements, helping DPOs prevent violations rather than react to them.

   Inspect AI is instrumental in transforming the DPO’s workload from manual audits to continuous AI-driven monitoring.

   Also Read: Cookie Consent Management & DPDP Rules: A Complete Guide for Indian Businesses

4. Cookies Manager

   Under DPDP governance rules, cookie banners and trackers fall under notice and consent requirements.

   Privy Cookies Manager enables DPOs to:

   • Scan and classify cookies

   • Configure compliant cookie banners

   • Track cookie categories like Necessary, Marketing, Statistics, etc.

   • Provide multilingual banner customization

   • Demonstrate tracking transparency during audits

   This gives DPOs complete governance over web tracking practices.

   Also Read: Different Types of Consent Under DPDP Rules

And with penalties under the DPDPA being significant, organizations cannot afford gaps in either cybersecurity or privacy governance.

Privy’s ecosystem has been designed to support the DPOs through immutable consent evidence, automated compliant management, AI-driven journey edits, RoPA and DPIA readiness, multilingual compliance, real-time dashboards, and cookie governance. There is no global tool that fully addresses the regulatory needs of India. However, Privy by IDfy was specifically designed to empower the DPOs and help enterprises across the nation become DPDP compliant.

Conclusion

The debate of DPO vs CISO is not at all about hierarchy, but it's more about the distinct responsibilities each has pertaining to the new era of privacy for India. A modern enterprise needs both a CISO and a DPO. While the former secures systems, the latter governs privacy and compliance.

Privy by IDfy, India’s first full-stack privacy and governance platform, was built by keeping exactly these thoughts in mind. If you also wish to be DPDP compliant in no time , empower your DPOs and do not wish a 250crore fine imposed on your business, get in touch with us at shivani@idfy.com so that we can help you become DPDP compliant in no time. Also, keep a lookout at this space for more articles on DPDP, privacy, and compliance.