Miracle Foundation India — DPDP Act Compliance Program
Built & implemented by MYITMANAGER’s CISO/DPO advisory • CISM • CISA • CIPP/E
Challenges
- Protecting children’s data (high‑sensitivity) across field operations and partners.
- Fragmented policies; no unified privacy governance or workflow ownership.
- Consent & notice design for multilingual, low‑connectivity environments.
- Third‑party processors (CRMs, payment gateways, M&E tools) with uneven controls.
- Breach readiness: notification to the Data Protection Board (DPB) and affected individuals.
DPDP Act — What It Requires (in practice)
- Lawful processing based on consent or legitimate use provided by law.
- Clear, itemized privacy notices; simple withdrawal of consent.
- Children’s data: verifiable parental/guardian consent; act in the best interests of the child; no tracking/targeted ads directed at children.
- Data principal rights: access, correction, erasure, and grievance redressal within defined timelines.
- Security safeguards proportional to risk; report personal‑data breaches to the DPB and affected individuals.
- Data retention limits: delete when purpose is met or on request, unless required by law.
- Processor management: written contracts, purpose limitation, and oversight.
- Cross‑border transfers permitted unless restricted by Government notification.
- Significant Data Fiduciary (SDF) — if designated: appoint DPO, conduct audits/assessments, additional obligations.
Our Approach — DPDP‑Only Compliance Build
- Rapid Gap Assessment: mapped current practices to DPDP obligations; prioritized child‑data risks.
- Governance Setup: nominated accountable owners; RACI for consent, rights, breach, vendor oversight.
- Consent & Notices: plain‑language, age‑appropriate templates; multilingual variants; withdrawal flows.
- Rights Operations: standardized intake, identity verification, SLA timers (access/correction/erasure), response playbooks.
- Children’s Data Safeguards: parental consent verification; guardrails against tracking/targeted ads; best‑interest checks.
- Processor Management: DPDP‑aligned DPA clauses; due‑diligence scorecards; continuous monitoring checklist.
- Security Controls (privacy‑centric): RBAC + MFA, encryption in transit/at rest, logging, MDM for field devices, secure sharing.
- Retention & Disposal: documented schedules; defensible deletion and crypto‑shredding where applicable.
- Breach Readiness: severity matrix, notification criteria, DPB/individual templates; tabletop exercises.
- Records & Accountability: processing inventory, consent/notice logs, rights ledger, breach register, vendor register.
Key Artifacts Delivered
- Privacy Policy (external) + Internal Data Protection Policy aligned to DPDP Act.
- Consent & Notice templates (adult/child/guardian) with withdrawal instructions.
- Data Subject Rights SOP + response templates; grievance redressal procedure.
- Processor DPA addendum + due‑diligence and monitoring checklists.
- Records of processing, consent logs, retention schedule, and breach register.
- Breach response runbook including DPB notification and stakeholder communication drafts.
Outcomes
- DPDP‑aligned program focused on children’s data protection and accountability.
- Operational playbooks for consent, rights handling, vendor oversight, and breach response.
- Defensible documentation and evidence trails to demonstrate compliance on demand.
- Clear SLAs and owners; reduced risk across field operations and digital platforms.
Operational SLAs (configured)
- Rights request triage within 24–48 hours; closure per defined statutory/organizational timelines.
- Breach assessment within 24 hours; notification triggers and templates pre‑approved.
- Quarterly vendor reviews; annual contract refresh for DPDP clauses.
- Biannual tabletop exercises for rights and breach scenarios.
Delivered by MYITMANAGER’s certified consultants: CISM • CISA • CIPP/E
Note: This case study describes a compliance enablement program and is not legal advice.
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