Data privacy & DPDPA law in Hyderabad — when personal data becomes legal liability, you need a lawyer who understands both.
SIRI Law LLP is India's only data privacy practice where your privacy lawyer and penetration tester work from the same office — your DPDPA compliance programme is built on real technical findings, not legal theory. We implement, test, and defend.
Why this deadline is not theoretical anymore
The Data Protection Board is staffed. The clock has a fixed end date.
For the first two years after the DPDP Act received Presidential assent in August 2023, "compliance window" was a fair way to describe where things stood — the Act existed, but the operational rules that actually tell an organisation what to build didn't. That changed on 13 November 2025, when the DPDP Rules 2025 were notified and the Data Protection Board of India was constituted. There is now a fixed, staggered timeline: Consent Manager registration opens in November 2026, and full compliance — consent architecture, privacy notices, data principal rights, breach protocols, all of it — is required by 13 May 2027.
That deadline matters more than the headline ₹250 crore penalty figure most articles lead with, because the penalty structure is more granular than a single number suggests. Failure to implement reasonable security safeguards carries up to ₹250 crore. Failure to notify the Board or affected individuals of a breach carries up to ₹200 crore. Mishandling children's data carries up to ₹200 crore. These aren't alternatives — a single incident that involves a security failure and a late notification can trigger penalties under multiple provisions at once, and they compound per instance.
The vendor question is the one most organisations underestimate. Every vendor who processes personal data on your behalf is a Data Processor under the Act — and if your vendor contracts have no DPA provisions, you carry unlimited DPDPA liability for your entire vendor ecosystem regardless of who actually caused a breach. This is the exact pattern behind our HealthTech case study below: a third-party diagnostic partner's breach, but the platform itself that carried the primary regulatory exposure.
Where organisations are actually exposed
Most organisations are not ready for the DPDPA. The ones who know this looked closely.
These are not hypothetical risks — they are the recurring pattern behind the gap assessments and breach engagements SIRI's privacy team handles most often.
Consent mechanisms don't meet the new standard
Most existing consent flows — bundled agreements, pre-ticked boxes, vague policy references — do not meet the DPDPA 2023 standard of specific, informed, free, and unconditional consent for defined purposes.
Vendor contracts create unmanaged liability
Every vendor who processes personal data on your behalf is a Data Processor. Most existing vendor agreements have no DPA provisions — meaning you carry unlimited DPDPA liability for your entire vendor ecosystem.
The notification window is not optional
CERT-In requires notification within 6 hours of awareness; the DPDPA layers its own Board notification obligation on top. Most organisations have no pre-built response protocol — meaning they cannot meet either deadline.
Technical audits reveal gaps legal reviews miss
DPDPA compliance cannot be achieved through document review alone. Insecure data flows, unlocked databases, and misconfigured cloud storage only appear in technical testing — not in a privacy policy read-through.
What we cover
Data privacy and cybersecurity legal services across the full compliance lifecycle
From initial DPDPA gap assessment through programme implementation, vendor management, and breach response — all under attorney-client privilege.
DPDPA 2023 Implementation
Data processing inventory, consent architecture design, privacy notice drafting, Data Fiduciary and Processor obligation mapping, breach notification programme, and full DPDPA implementation.
- Data processing inventory and mapping
- Consent architecture design
- Fiduciary and Processor obligation mapping
- Breach notification programme build
Privacy Programme Design
Enterprise privacy governance frameworks, data classification policy, retention and deletion schedules, cross-border transfer assessments, privacy by design integration, and DPO advisory.
- Data classification and retention policy
- Privacy by design integration
- DPO advisory and appointment support
- Board-level governance documentation
Vendor & DPA Management
Audit of your entire vendor ecosystem for DPDPA Data Processor obligations, DPA drafting and negotiation, sub-processor management frameworks, and incident notification contractual requirements.
- Vendor ecosystem DPDPA audit
- DPA drafting and negotiation
- Sub-processor management frameworks
- Contractual incident notification terms
Breach Response & Regulatory Defence
Immediate breach response legal counsel, CERT-In 6-hour notification support, DPDPA Board filing, regulatory investigation defence, and post-incident governance review — 24/7 for retainer clients.
- CERT-In 6-hour notification support
- Data Protection Board filing
- Regulatory investigation defence
- Post-incident governance review
Cross-Border Data Transfer Advisory
Legal assessment of international data transfers under DPDPA, standard contractual clauses, data localisation obligations, and cross-border DPA negotiation for multinational operations.
- International transfer legal assessment
- Standard contractual clause drafting
- Data localisation obligation review
- Multinational DPA negotiation
DPDPA Audit Readiness
Documentation review, evidence compilation, regulatory submission preparation, Data Protection Board enquiry response, and board-level accountability demonstration for organisations facing scrutiny.
- Documentation review and evidence compilation
- Regulatory submission preparation
- Board enquiry response support
- Board-level accountability demonstration
Evidence, not guesswork
The ₹250 crore headline is one number among several — here's the actual structure
Most coverage of DPDPA penalties quotes the single largest figure. The Act's penalty schedule is more specific than that, and the specifics are what actually determine your exposure.
| Violation type | Maximum penalty | Triggered by |
|---|---|---|
| Security safeguard failure | ₹250 crore | Failing to implement reasonable security measures to prevent a breach |
| Breach notification failure | ₹200 crore | Failing to notify the Data Protection Board or affected individuals |
| Children's data mishandling | ₹200 crore | Processing children's personal data without verified parental consent |
| Other specified violations | Up to ₹50 crore | Lesser procedural and documentation failures |
| Consent Manager non-compliance | Board-determined | Registered Consent Managers failing their statutory obligations |
Penalties can be imposed per instance and per provision — a single incident touching multiple obligations (for example, a security failure followed by a late notification) can trigger separate penalties that compound. Source: DPDP Act 2023 penalty schedule; DPDP Rules 2025 (Gazette G.S.R. 846(E), 14 Nov 2025). Figures current as of publication — verify against the latest Data Protection Board guidance before relying on a specific figure.
What readiness actually looks like
Four numbers that separate a compliant programme from a paper one
Mandatory reporting window from awareness of a cybersecurity incident — independent of and running alongside DPDPA Board notification obligations.
Minimum preparation timeline for a compliant DPDPA programme — consent redesign, vendor DPA rollout, and breach protocol build take real time to execute properly.
Representative scale of the vendor ecosystem our fintech engagement below had to bring under compliant Data Processing Agreements.
Simultaneous legal and technical forensic response time for retainer clients — from a single call, not a coordination exercise across two vendors.
How we implement
DPDPA compliance in four structured stages
A proven implementation methodology that produces a legally defensible, technically validated privacy programme — not just a document.
Gap assessment
Technical audit of data flows, consent mechanisms, and vendor integrations combined with legal review of existing policies and contracts, producing a prioritised gap matrix.
Weeks 1–2Programme design
Consent architecture design, privacy notice drafting, data processing inventory, vendor DPA templates, breach response playbook, and governance policy suite.
Weeks 2–4Implementation
Consent flow implementation support, vendor DPA negotiation, governance sign-off, staff awareness delivery, and technical validation by our security team.
Weeks 4–8Managed compliance
SIRI Shield retainer providing continuous DPDPA monitoring, regulatory updates, contract review, annual re-assessment, and 24/7 incident response priority.
OngoingCase study · DPDPA breach response
HealthTech platform avoids ₹180 Cr DPDPA liability after a third-party diagnostic partner breach
A Hyderabad HealthTech platform with 8 lakh registered users suffered a breach through a third-party diagnostic partner. SIRI Law LLP filed the CERT-In notification within 5.5 hours, led the forensic investigation establishing third-party root cause, drafted the regulator-facing incident report, and managed the investigation to closure.
The Data Protection Board investigation closed with no penalty against the platform — a direct result of documented consent architecture, a pre-built breach response protocol, and a clean chain of evidence establishing the root cause sat with the vendor, not the platform's own systems.
Representative matters
Typical engagements
All matters described generically to protect client confidentiality.
Full compliance rollout
Advised a fintech company on full DPDPA compliance — consent architecture redesign, updated privacy notices, DPA templates for 40+ vendors, and a documented grievance mechanism.
Coordinated regulatory response
Managed legal breach response for a healthcare provider following unauthorised access — coordinating CERT-In notification, patient notification strategy, and regulatory engagement.
Training data framework
Advised an AI product company on a GDPR and DPDPA-compliant training data governance framework, including data source audits and consent validation.
Successful regulatory defence
Represented a company facing a consumer complaint for alleged misuse of personal data, successfully defending with documentation of consent and purpose limitation.
Why SIRI
The only privacy practice in India that tests what it advises on
Every SIRI DPDPA implementation is validated by our in-house technical team — we test your actual consent flows, audit your real data processing systems, and find vendor contract gaps before the regulator does.
Technical validation of legal compliance
We don't just draft your privacy policy — we test whether your actual data flows match it. Our penetration testers audit the systems your privacy lawyers advise on, closing the gap between legal documentation and technical reality.
24/7 breach response
CERT-In's 6-hour mandatory notification window doesn't pause for business hours. We are the only privacy firm in India that can mobilise simultaneous legal response and technical forensics from a single call, within 2 hours for SIRI Shield clients.
Privilege on technical findings
All DPDPA gap assessments and privacy audits are conducted under privilege — findings generally cannot be subpoenaed by the Data Protection Board in regulatory investigations, unlike a standalone consultant's report.
End-to-end implementation
We don't hand over a gap report and walk away. We implement — consent flows, vendor DPAs, breach playbooks, governance documentation — producing a compliant, defensible programme, not just a diagnosis.
The comparison
Without SIRI versus with SIRI
| Capability | Privacy consultant or generalist firm | SIRI Law LLP — legal + technical |
|---|---|---|
| Delivery model | Gap report produced and handed over — implementation left to your internal team | End-to-end implementation: consent flows, vendor DPAs, governance, staff awareness |
| Technical validation | Policies drafted without testing whether actual systems comply | Every implementation validated by in-house penetration testing |
| Privilege over findings | Consultant reports are typically discoverable in regulatory investigations | Full attorney-client privilege over all legal and technical findings |
| Breach response capability | Legal advice during business hours; forensics needs a separate vendor engagement | 24/7 combined legal, technical, and forensic response from one call |
Frequently asked
Data privacy and DPDPA, answered directly
When does full DPDPA 2023 compliance become mandatory?
The DPDP Rules 2025 were notified on 13 November 2025, starting an 18-month phased implementation. Consent Manager registration opens in November 2026, and full compliance — consent architecture, privacy notices, data principal rights handling, and breach protocols — is required by 13 May 2027. The Data Protection Board of India is already operational and accepting complaints, so treating this as a distant deadline is a risk in itself.
What is the difference between a Data Fiduciary and a Data Processor?
A Data Fiduciary determines the purpose and means of personal data processing. A Data Processor processes data on behalf of a Fiduciary. Many organisations are both simultaneously — Data Fiduciaries for their own data collection and Data Processors for their enterprise customers. SIRI maps your specific obligations across both roles.
What happens if my vendor causes a data breach — am I still liable?
Yes. You remain a Data Fiduciary responsible for personal data processed on your behalf, regardless of whether a vendor caused the breach. You are still obligated to notify the Data Protection Board, potentially notify affected individuals, and manage the regulatory and legal response. This is why vendor DPAs and audit rights are critical — and exactly the pattern behind our HealthTech case study above.
How is the ₹250 crore DPDPA penalty actually structured?
It is not a single flat fine. The Act sets different maximum penalties by violation type: failure to implement reasonable security safeguards carries up to ₹250 crore, failure to notify the Board or affected individuals of a breach carries up to ₹200 crore, mishandling children's data carries up to ₹200 crore, and other violations carry lower caps. Penalties can accrue per instance and per provision, so multiple failures in a single incident can compound.
What does Significant Data Fiduciary status mean?
Organisations designated as Significant Data Fiduciaries face additional obligations: appointing a DPO, conducting DPIAs, engaging independent data auditors, and additional governance documentation requirements. The government designates organisations based on data volume, sensitivity, and risk profile — and with the Board now actively staffed, this designation carries a realistic prospect of audit.
Can you help us respond to a CERT-In mandatory breach notification?
Yes, within the 6-hour mandatory reporting window. SIRI Shield retainer clients receive 2-hour mobilisation. We file the CERT-In notification, manage the regulatory response, coordinate technical forensic investigation, and handle follow-up enquiries — all under attorney-client privilege.
Ready when you are
DPDPA compliance is not a future obligation. It is a present one.
Book a confidential DPDPA assessment with SIRI Law LLP. We will assess your current data processing activities, identify your compliance gaps, and design a practical implementation programme.
Related services
Other ways SIRI Law LLP supports your compliance posture
Cybersecurity testing services
Penetration testing, red teaming, and technical validation for your DPDPA programme.
AI & emerging technology law
EU AI Act compliance, LLM vendor contracts, and AI training data governance.
Corporate & commercial law
M&A due diligence and contracts, with cyber risk assessed inside every deal.
Visit or contact us
SIRI Law LLP — Hyderabad, India
| Registered office | HITEC City, Madhapur, Hyderabad, Telangana 500081, India |
| Telephone | +91 79819 12046 |
| info@sirilawllp.com | |
| Other offices | New Delhi, India · Austin, Texas, USA · Online worldwide |
| Hours | Mon–Sat, 9:30 AM – 7:00 PM IST · Emergency line 24/7 |