DATA PRIVACY & PROTECTION

Governing Data, Protecting Trust

India’s Digital Personal Data Protection Act, 2023 and the DPDP Rules, 2025 mark a transformative shift in the regulatory landscape for data governance. KBD advises organisations across sectors on building robust, future-ready privacy and data protection frameworks that are both legally compliant and operationally practical. The Firm assists clients in navigating the full spectrum of data protection obligations — from initial compliance mapping and gap assessment through policy architecture, vendor and supply-chain management, cross-border transfer compliance and ongoing regulatory advisory.

KBD brings extensive experience advising clients across retail, e-commerce, FMCG, manufacturing and technology sectors on data protection, governance, cybersecurity, AI governance, global transfer compliance and digital transformation. The Firm’s approach is grounded in a thorough understanding of each client’s data environment — mapping how personal data is collected, used, stored, shared and deleted — and translating statutory obligations into practical, business-aligned frameworks that organisations can implement and sustain.

Scope of Services

DPDP Compliance & Gap Assessment

• Data inventory and data flow mapping across business units
• Risk-based gap assessments against statutory requirements
• Data Processing Register preparation under Section 8(6)
• Remediation roadmaps with prioritised action plans
• Structured compliance workshops with business and functional teams

Policy, Notice & Consent Architecture

• Data Protection & Privacy Policies
• HR and Employee Data Policies
• Customer Data Policies
• Retention and Deletion Policies
• Breach Response and Incident Management Policies
• CCTV and Surveillance Policies
• Privacy notices for digital and physical touchpoints
• Consent frameworks, templates and withdrawal mechanisms

Contract & Supply-Chain Compliance

• Vendor and processor contract reviews and updates
• DPDP-compliant data processing clauses for vendors, marketplaces and franchise partners
• Data processing agreements
• Supply-chain compliance frameworks and trackers

Cross-Border Transfers & Data Protection Impact Assessments

• Cross-border data transfer mapping and compliance under Section 16
• Cross-Border Transfer Registers
• Data Protection Impact Assessments (DPIAs) for high-impact processing activities
• Risk mitigation matrices and safeguard recommendations

Rights Management & Governance

• Operationalisation of Data Principal rights under Sections 11-13
• SOPs for data access, correction, erasure and grievance management
• Data Protection Lead and Grievance Officer frameworks
• Identity verification and escalation workflows
• Compliance training for management, HR, IT and franchise teams

Cybersecurity & Breach Response

• Cybersecurity risk advisory
• Breach response planning and incident management frameworks
• Post-breach regulatory compliance and notification support
• Security audit support and vulnerability assessments

Significant Data Fiduciary & Ongoing Compliance

• Section 10 readiness assessments for Significant Data Fiduciaries
• Enhanced security measures and Board-level reporting structures
• Annual and bi-annual compliance reviews
• AI governance frameworks and privacy-by-design advisory
• Ongoing regulatory advisory and policy updates

REPRESENTATIVE MATTERS

• Advised and assisted a leading omnichannel retail company operating over 1,300 stores and franchise networks on end-to-end DPDP Act compliance, including data mapping across retail, e-commerce, HR and supply-chain functions, enterprise-wide policy architecture, vendor and franchise contract updates, cross-border transfer compliance and implementation training.
• Advised and assisted the subsidiary of a leading Swedish cable solutions company in relation to a cyber attack on its IT systems, resulting in the breach and exfiltration of personal data of employees, including post-breach regulatory compliance and remediation.
• Advised multinational clients on cross-border data transfer compliance, including mapping international data flows, assessing applicable transfer mechanisms and preparing Cross-Border Transfer Registers under the DPDP Act.
• Assisted clients in developing comprehensive data governance frameworks, including data inventories, data flow diagrams and Data Processing Registers across complex, multi-business-unit organisations.
• Drafted and implemented enterprise-wide data protection and privacy policies, privacy notices and consent frameworks for clients across the retail, FMCG and technology sectors.

• Advised clients on vendor and supply-chain data compliance, including review and update of contracts with technology vendors, cloud providers, logistics partners and marketplace operators to embed DPDP-compliant data processing restrictions and breach-response obligations.
• Conducted Data Protection Impact Assessments for high-impact processing systems, including e-commerce platforms, biometric systems, CCTV networks and AI/ML tools.
• Assisted clients in operationalising Data Principal rights, including designing SOPs for data access, correction, erasure and grievance management, and deploying ticketing workflows across business units.
• Advised clients in preparation for potential notification as Significant Data Fiduciaries under Section 10 of the DPDP Act, including enhanced security frameworks, periodic audit structures and Board-level reporting.
• Provided ongoing compliance advisory services to clients on regulatory updates to the DPDP framework, new system impact assessments and breach response support.