DPDPA 2023 Compliance & Privileged Audit — SIRI Law LLP

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Privilege EnforcedEvery technical finding, protected

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DPDPA 2023 · Privileged Compliance Audit

DPDPA compliance, built under privilege — not bolted on after.

Q: How long does a full DPDPA compliance programme take?

For most mid-market organisations, 8–12 weeks from gap assessment to board-ready certification, though this varies with the complexity of your data flows and how many vendor and cross-border transfers are involved.

Q: Can you certify us for investor due diligence?

Yes — the Board Certification Pack combines the legal opinion and technical audit result into a single document that your investors' counsel can review directly, rather than two disconnected reports.

Q: What happens if the audit finds something serious?

It gets fixed, and how disclosure is handled — to a board, an investor, or a regulator — is a legal judgment made with you. This is general information and not legal advice on your specific situation.

A standalone compliance vendor hands you a gap report and walks away. We run the same technical audit — consent architecture, data-flow mapping, breach readiness — directed by retained counsel, so the findings and the fix are backed by an attorney who can also stand in front of your board, your investors, or the Data Protection Board if it comes to that.

Book Privileged Audit Speak to an Attorney Now

₹500Cr Max DPDPA fine We keep you off the wrong side of that number

8–12 wks Typical to board-ready Engagement to certification, case-dependent

Privileged Attorney-directed testing Technical audit run under legal engagement, not a standalone vendor report

1 Integrated team Legal and technical specialists, one retainer

The Privilege Gap

Your gap report can be used against you.

Most organisations buy a DPDPA compliance audit the same way they'd buy a website audit — from a consultant or a boutique GRC vendor. That approach has a structural weakness that only becomes visible after a breach or a regulatory inquiry.

Standard Vendor Audit

The exposure most firms don't mention

A gap-assessment report from an independent consultant is generally not covered by legal privilege, and may be discoverable by a regulator or opposing counsel in a later dispute.
Findings are handed over as a technical document, with no assessment of how each gap translates into regulatory or litigation exposure.
Remediation advice addresses the technical fix only — not whether the fix is legally sufficient to satisfy the Act's requirements.
If a breach follows, your own audit trail can become evidence of a known, unaddressed gap.

SIRI Privileged Model

Testing directed by retained counsel

The technical audit is scoped, directed, and reported to retained counsel as part of a legal engagement — extending the same privilege doctrine used for legal work to the technical findings.
One integrated report addresses both the technical gap and its regulatory consequence, in language your board and your regulator can both work with.
An attorney — not only an engineer — signs off on your board-readiness position.
If a matter later goes to a regulator or a court, the same team that ran the audit can represent you.

The privilege doctrine referenced above is real but fact-dependent — it turns on how the engagement is structured, not on the label attached to it. Whether it applies to your specific engagement should be confirmed by your retained counsel before you rely on it. [Statutory basis: Section 126, Indian Evidence Act / Section 132, Bharatiya Sakshya Adhiniyam 2023 — verify current citation with counsel.]

Core Capabilities

What the engagement actually delivers.

Provisions below are described in general terms. Specific section citations are finalized with retained counsel before any deliverable is issued to a client or regulator.

Consent & Notice Architecture

Multilingual consent flows and notice language built to the Act's consent standard — not a cookie banner retrofit. Reviewed jointly by counsel and the technical team before it ships.

Data Principal Rights Workflow

Access, correction, erasure, and grievance-redressal processes mapped end-to-end, with response-time tracking built into your existing systems rather than a separate spreadsheet.

Breach Notification Readiness

A board-approved breach response playbook aligned to your CERT-In notification window and your obligations toward the Data Protection Board, drafted before you need it.

Attorney-Directed Penetration Testing

A technical assessment of the systems that actually process personal data, scoped and reported under the legal engagement described above — not a standalone vendor report.

Significant Data Fiduciary Assessment

Evaluation against the Act's heightened obligations for high-volume or high-risk processing — including whether any additional audit, DPO, or impact-assessment requirements apply to your organisation.

Board Certification Pack

A single sign-off document for your board and investors — legal opinion and technical audit result in one file, not two reports that don't reference each other.

Engagement Methodology

From first call to board certification.

Privileged Scope & Discovery

The engagement opens as an attorney-client relationship. Your data flows, vendor list, and processing activities are mapped under privilege before any technical work starts.

Technical & Legal Audit

Penetration testing, data-flow mapping, and consent-architecture review run alongside legal gap analysis — one workstream, not two sequential ones.

Remediation & Drafting

Findings translate directly into fixed consent flows, updated policies, and a prioritized technical remediation roadmap — not a PDF of recommendations nobody actions.

Board Certification

A single sign-off pack — legal opinion plus technical evidence — ready for your board, your investors, or a regulator to review.

In Practice

This is what the audit actually looks like.

One real engagement, run the way described above.

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Healthtech — DPDPA Compliance 0 findings

A Series B healthtech had investor due diligence eight weeks away and an unaudited DPDPA posture. The compliance review closed with zero critical findings, on schedule.

Read outcome

Frequently Asked

Questions we answer
before every DPDPA engagement.

Do we actually need a privileged audit, or is a standard consultant enough?

Depends on your risk profile. If you process sensitive personal data at scale, are heading into investor due diligence, or have any history of a security incident, the privilege question stops being theoretical — a discoverable gap report becomes evidence against you if something goes wrong later. For lower-risk organisations, a standard consultant audit may be sufficient. We'll tell you honestly which category you're in during the scoping call, not just sell you the bigger engagement.

What does "Significant Data Fiduciary" mean, and does it apply to us?

The Act sets a higher bar of obligations — additional audits, DPO appointment, impact assessments — for entities processing personal data at a volume or sensitivity the government designates as significant. Whether your organisation meets that threshold depends on criteria set by government notification, which we confirm as part of the initial assessment rather than assuming either way.

How long does a full DPDPA compliance programme take?

For most mid-market organisations, 8–12 weeks from gap assessment to board-ready certification, though this varies with the complexity of your data flows and how many vendor and cross-border transfers are involved. Legal and technical work run in parallel rather than in sequence, which is what keeps the timeline where it is.

Is our penetration test report protected if we're later investigated?

When testing is scoped and directed by retained counsel as part of a legal engagement, the resulting report can carry attorney-client privilege protection — the same doctrine used for legal work extended to technical findings. This is fact-dependent on how the engagement is actually structured, not automatic from hiring a law firm. Your retained counsel will confirm the specific protection that applies to your engagement.

Can you certify us for investor due diligence?

Yes — the Board Certification Pack is built for exactly this: a single document combining the legal opinion and technical audit result that your investors' counsel can review directly, rather than two disconnected reports they have to reconcile themselves.

What happens if the audit finds something serious?

It gets fixed, and how we handle disclosure — to a board, an investor, or a regulator — is a legal judgment made with you, not a default assumption. That's a large part of why the audit is attorney-directed in the first place: a standalone technical vendor has no framework for that decision. This is general information and not legal advice on your specific situation; talk to us directly about what you're facing.

Talk To Us Today

Every day without integrated cover
is a day of open exposure.

Breach response, DPDPA compliance, or an ongoing retainer — the gap between your legal exposure and your security posture closes with one call. Not next quarter. Today.

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