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NPCI Data localisation checklist

1. Understanding Regulatory Requirements

Review NPCI guidelines on data localisation.

Identify specific data types that need to be localised.

Understand penalties for non-compliance.

2. Data Inventory Assessment

Conduct a comprehensive data inventory.

Classify data based on sensitivity and regulatory requirements.

Identify data storage locations and processing activities.

3. Infrastructure Readiness

Assess existing IT infrastructure for compliance with localisation.

Evaluate cloud service providers for data storage within India.

Plan for necessary upgrades or changes to infrastructure.

4. Data Migration Plan

Develop a data migration strategy for localised storage.

Establish timelines and milestones for data migration.

Identify potential risks and mitigation strategies during migration.

5. Compliance and Governance

Create data governance policies aligned with NPCI guidelines.

Define roles and responsibilities for data management.

Implement regular compliance audits and assessments.

6. Security Measures

Assess current data security measures to ensure compliance.

Implement encryption and access controls for sensitive data.

Plan for incident response and breach notification processes.

7. Staff Training and Awareness

Develop training programs on data localisation requirements.

Conduct workshops for staff on compliance and data handling.

Establish a culture of data protection within the organization.

8. Monitoring and Reporting

Set up monitoring systems for ongoing compliance.

Develop reporting mechanisms for data localisation status.

Regularly review and update practices based on regulatory changes.

9. Stakeholder Communication

Communicate data localisation plans to stakeholders.

Provide updates on compliance progress and challenges.

Engage with regulatory bodies for guidance and clarification.

10. Review and Continuous Improvement

Establish a process for periodic review of data localisation practices.

Solicit feedback from staff and stakeholders.

Update policies and procedures based on lessons learned.

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