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Data Privacy Module

Applies to: Data Privacy · Which modules do I have?

Purpose

Configure the module that supports obligations under India's Digital Personal Data Protection Act: notices, consent, grievances and the evidence needed to demonstrate compliance.

Audience

Data protection officers, compliance teams, and administrators configuring the module.

Prerequisites

  • Module licensed and enabled
  • Privacy notice content drafted and approved by the customer's legal advisers
  • Processing purposes defined by the customer
  • Grievance process and owner established
  • Downstream systems identified, if consent state must propagate

This page describes what the software does. The customer's obligations under the Act are determined by their circumstances and their legal advisers, not by this portal. See Data Protection and DPDP.

Steps

1. Define purposes first

A purpose describes why personal data is processed. Consent is captured against a purpose, so purposes must exist before any consent is meaningful.

Practice Reason
Specific rather than broad "Processing invoices" is defensible; "business operations" is not
Defined by the customer, not the implementer It is a legal determination
Retired rather than deleted when no longer used Existing consent records still reference it

2. Author and version the notice

Notices are authored, versioned, and a specific version is published.

Versioning is the most operationally important feature in this module. Consent is recorded against a specific version of a specific notice, so it remains meaningful after the notice changes. A consent record that cannot say what was consented to is difficult to defend.

Step Note
Author the notice Content supplied by legal advisers
Create a version Each material change is a new version
Publish the version Only a published version can be consented to
Keep superseded versions They are the evidence for consents captured under them
Capability Use
Capture Record consent against a purpose and published notice version
Withdraw Record withdrawal, with a timestamp
History The full sequence for a data principal
Consent check Query whether valid consent exists before processing

Build the consent check into any downstream process that depends on it. A consent record that nothing consults is a record, not a control.

4. Configure grievance handling

Record grievances, assign an owner, resolve them. A grievance process with no named owner is a process that misses its response window.

5. Configure downstream propagation

Where consent state must reach other systems:

Mechanism Use
Webhooks Push notification to a downstream endpoint
Connectors Configured integrations with delivery logging

Both keep delivery logs. Check them — a withdrawal that fails to propagate leaves a downstream system processing on a basis that no longer exists, and nothing will surface that unless someone looks.

6. Configure evidence packs and the audit ledger

Artefact Purpose
Evidence pack A printable set of evidence for a point in time, generated on demand
Audit ledger A tamper-evident record of privacy-relevant actions

Generate an evidence pack once during implementation. It reveals gaps in configuration far more effectively than a review of the configuration screens.

7. Configure the public-facing surfaces

Where used, the module exposes a public privacy notice and a vendor or data-principal privacy centre for capturing consent, viewing history and raising grievances. Confirm these are reachable and correct before publicising them.

Validation

Check Method Pass condition
Purposes defined Review the list Specific and approved by the customer
A notice is published Open the published notice Present, with a version identifier
Consent names its version Capture a test consent and inspect it Names the purpose and the notice version
Withdrawal works Withdraw the test consent Recorded with a timestamp
History is complete View the principal's history Shows capture and withdrawal in sequence
Consent check returns correctly Query before and after withdrawal Reflects the current state
Grievance flow works Raise and resolve a test grievance Recorded end to end, with an owner
Propagation works Test a webhook or connector Delivered, and visible in the log
Evidence pack generates Generate one Complete and printable
Audit ledger records Perform an action and inspect the ledger Entry present
Public surfaces reachable Open them from outside the network Load correctly
Superseded versions retained Review notice history Earlier versions still available

Troubleshooting

Symptom Cause Action
Consent records do not identify what was consented to Captured without a published notice version Re-capture against a published version
Cannot publish a notice No version created, or content incomplete Create and complete a version first
Withdrawal not reflected downstream Webhook or connector failing Check the delivery log and re-test. This is the failure that leaves downstream systems processing without a basis
Evidence pack incomplete Purposes or notices not fully configured Complete the configuration and regenerate
Grievance response window missed No owner assigned Assign one and add grievance review to the operational routine
A purpose cannot be deleted Existing consent references it Retire it instead. Deleting would orphan the consent records
Public privacy centre unreachable Not published, or blocked by network policy Confirm reachability from outside the network before publicising it
Module absent Not licensed, or not enabled for the registration See Modules and Licensing
Retention conflicts with a deletion request Statutory retention applies to compliance evidence Statutory retention wins. Record the decision and its basis