Data Principal Rights Under DPDP: How to Operationalize Requests in 15 Days

Digital Personal Data Protection (DPDP) Act has changed India’s focus of compliance to data collection to rights-based accountability. Companies are no longer judged based on the level of security at which they keep the personal information but also the level at which they can act in case the individuals decide to invoke their rights. The Act stipulates that Data Fiduciaries shall have in place mechanisms such that Data Principals have access to, can correct, delete, or withdraw consent to, or be an employee of, Data Fiduciaries, and most importantly, act within specified time frames (which is generally operationalized as a 15-day internal service standard to be regulatory ready). 

The actual issue faced by many businesses is not the interpretation of the law but the practice of rights demands on a large scale. Organizations that lack structured workflows are prone to delays, inconsistent treatment and regulatory exposures. In this article, we introduce a practice step-by-step SOP aimed at controlling Data Principal rights requests in an efficient way without jeopardizing the compliance and operational resilience. 

Table of Content

Understanding Data Principal Rights Under DPDP

Step-by-Step SOP to Operationalize Requests in 15 Days 

When Can Organizations Decline a Request? 

Technology’s Role in Scaling DPDP Rights Management 

Moving From Compliance Obligation to Trust Strategy 

Understanding Data Principal Rights Under DPDP 

Under the DPDP model, individuals (Data Principals) are entitled to a number of rights which are enforceable, which include:  

• Entitlement to get information regarding personal data under processing. Immediate  

• right to correction and erasure.  

• Right to withdraw consent  

• Redressal of grievance rights. 

These rights have to be operationalized by cross-functional interdependency between IT, legal, customer support, and security teams. The properly designed SOP facilitates the consistency of the requests processing, the maintenance of the auditable records, and the adherence to the response deadlines. 

Step-by-Step SOP to Operationalize Requests in 15 Days 

Step 1: Establish Request Intake Channels (Day 0–1) 

The organizations are advised to offer various standardized routes of rights requests there can be a portal of privacy, an email address, a customer dashboard or an interface through a mobile app. The individual intake channels must automatically create a request ID and a confirm notification to the Data Principal. 

Best practice: 
Make sure that forms necessary to intake essential information to be included like request type, identity details, consent reference and contact information. Do not over collect data at this stage because it might be disproportionate. 

Real-world scenario: 
A lending system in the digital format gets hundreds of data access requests each month. Through the introduction of privacy self-service portal that supports automated ticketing, the company lowered the acknowledgment of the request of three days to below an hour. 

Step 2: Identity Verification (Day 1–3) 

Organizations should ensure that a requester is the authentic Data Principal or authorized representative before they process any request. Identity verification is to be performed according to the risk-based authentication strategies: 

• OTP authentication associated with registered email/mobile.  

• Authentication of registered users to log in to their accounts.  

• Additional KYC check on high risk requests (e.g., deletion of financial records).  

Record the verification procedure applied to audit. 

Key consideration: 
When the verification is too rigid, it may frustrate the user on the other hand; when it is too lenient, the organization is subjected to unauthorized disclosures. Risk-based identity confirmation finds a middle ground. 

Step 3: Request Logging and Classification (Day 2–4) 

All approved requests are to be registered into an internal privacy request management system with the following information: 

• Request ID 

• Request category (access, correction, erasure, withdrawal) 

• Date of receipt and verification 

• Responsible internal owner 

• Target completion date 

The classification provides prioritizing and the possibility to route the workflow to corresponding departments (HR, customer operations, finance, etc.) automatically. 

Real-world scenario: 
A customer marketplace mapped its customer data on 12 internal systems through e-commerce. When the company wrote system ownership on the request on the request logging, internal routing delays were decreased by approximately 40 percent. 

Step 4: Data Discovery and Processing (Day 4–10) 

After the request has been allocated, the teams responsible should find all locations of the personal data of the individual in the systems. This includes: 

• Active databases 

• Backup repositories (where feasible) 

• Processors of the data who are third parties. 

Automated data discovery tools save much manpower and enhance accuracy of response. In case of correction or erasure requests, the changes should be synchronized in all specific environments. 

Operational insight: 
Companies with current data maps and process catalogues are much more responsive since data paths and system proprietorships are recorded already. 

Step 5: Response Preparation and Approval (Day 10–13) 

Organizations must perform a compliance review before sending the final response so that: 

• Data requested is complete and accurate.  

• The appropriate redacting of any legally exempt information is done. 

• Correction/erasure (processing actions) are checked and fulfilled. 

• Third-party processors are notified where necessary. 

The response of high-risk or complex case should be approved by legal or privacy teams to keep regulatory defensibility. 

Step 6: Final Response Delivery and Closure (Day 13–15) 

The last answer must entail: 

• Action taken 

• Data provided (if access request) 

• Confirmation of correction/erasure 

• Any partial denial can be explained for the following reasons. 

• Grievance escalation contact details 

All request records should be archived securely for compliance audits 

When Can Organizations Decline a Request? 

DPDP permits some exceptions in which organizations can refuse or satisfy requests in parts, which include: 

• In situations where there is a legal or other regulatory requirement to retain.  

• When disclosure would reveal trade secrets or proprietary algorithms 

• In case of unable to verify identity. 

• In repetitive requests or requests which are plainly excessive.  

In these instances, they should also have a clear written explanation and a grievance redressal mechanism in the organizations. 

Technology’s Role in Scaling DPDP Rights Management 

The operation of a manual workflow is not sustainable in an organization that receives a high number of requests every day. Automated privacy request orchestration platforms are becoming popular in organizations that combine identity verification, workflow automation, data discovery and response tracking into a single platform.  

Examples of the solutions used to operationalize Data Principal rights include the CryptoBind Data protection and consent governance frameworks, which allow enterprises to:  

• Secure identity validation workflows 

• Request logging and SLA tracking Automated. 

• Distributed data discovery of encrypted data. 

• Ready audit compliance reporting.  

Organizations can experience regulatory preparedness as well as user trust on a large scale by integrating privacy by design principles into their operational systems. 

Moving From Compliance Obligation to Trust Strategy 

Within 15 days, to operationalize Data Principal rights is not only a compliance measure, but it is also a trust-building competence. Quick, transparent and secure responsiveness translates to accountability and instills customer confidence in the organization and minimizes regulatory risk. 

Although policy documents will not determine the future of privacy compliance, it will be determined by the maturity of the execution, that is, how smoothly organizations incorporate rights management in their everyday activity. Companies that invest now in standardized SOPs, automation and governance frameworks will be well placed to address the expectations of DPDP as well as offer a frictionless user experience. 

Organizations which emerge as the winners in the DPDP age will be those that will not respond to any request to establish a right as operational strain, but as the quantifiable measure of digital trust.