Named statutory DPO
A qualified individual formally appointed, published in your privacy notices and registered with the relevant authority as your point of contact.
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Executive summary
DPDPA requires Significant Data Fiduciaries to appoint an India-based Data Protection Officer accountable to the board. The role demands independence, expertise and availability — expensive to recruit and wasteful to keep idle. This engagement provides a named, qualified DPO carrying the statutory functions, backed by the full practice, with independence protected contractually.
India's Digital Personal Data Protection Act requires Significant Data Fiduciaries to appoint a Data Protection Officer based in India and accountable to the board. GDPR imposes a parallel obligation on many organisations serving European data principals. The role demands independence, expertise and availability — a difficult combination to recruit for and an expensive one to keep idle.
Our Virtual DPO service provides a named, qualified professional who carries out the statutory functions, backed by the full DATATrust India practice. You get continuity of a single relationship with the depth of a team behind it.
The engagement is deliberately structured to preserve independence: the DPO reports to your board, records advice given, and is contractually protected from being penalised for the advice they provide.
The DPO staffing problem
Each capability below is a discrete workstream with its own owner, deliverables and definition of done.
A qualified individual formally appointed, published in your privacy notices and registered with the relevant authority as your point of contact.
Handling of correspondence with the Data Protection Board of India and supervisory authorities, plus the grievance channel required by DPDPA.
Independent assessment of high-risk processing, with documented advice and a clear record of where residual risk was accepted and by whom.
On-call guidance for product, marketing and procurement teams, with defined response times and a logged advice trail.
Scheduled compliance monitoring against your privacy programme, reported to the board with findings and required actions.
Independent oversight of personal data breach assessment and notification decisions, including the reasoning behind a decision not to notify.
Each benefit is stated with the commercial consequence attached, because a capability without a consequence is a feature list.
A named, qualified, India-based DPO with a board reporting line and a documented advice trail including advice not followed.
Answers every question a regulator asks about the arrangement, in an afternoon.
Contractual protection against commercial penalty for unwelcome findings, and no conflict with a security or legal remit.
Removes the structural conflict that supervisory authorities specifically flag when the CISO or GC holds the role.
During an incident the DPO moves to daily availability with incident and legal specialists behind them.
Avoids the failure mode where a part-time internal DPO must abandon their day job for a fortnight.
A role needing eight hours in a quiet month and eighty in a breach week, resourced accordingly.
Delivers senior statutory capability without carrying an underemployed executive salary.
Phases overlap deliberately — design begins before assessment closes, so the programme does not stall waiting for a document to be signed off.
Weeks 1–2
Match a qualified DPO to your sector and data profile, agree the charter, and complete formal appointment and publication.
Weeks 2–5
Rapid immersion in your processing landscape, existing documentation, vendor set and open privacy issues.
Weeks 5–12
Close the highest-priority gaps found during onboarding and establish the advisory, DPIA and grievance workflows.
Ongoing
Steady-state delivery: advisory, monitoring, DPIA review, breach oversight and board reporting on an agreed cadence.
Annual
Annual review of the engagement scope against your risk profile, with the option to transition to an in-house DPO we help you recruit.
Named artefacts, listed in the statement of work. If it is not on this list, we will tell you before you sign rather than after.
Sector constraints change the delivery approach more than they change the obligations. These are the sectors this methodology is built around.
Fixed fee for defined scopes, retainer for ongoing services. We do not price advisory work on time and materials, because that misaligns our incentive with your outcome.
2 weeks
Organisations assessing whether they need an appointed DPO
Commercial basis: Fixed fee
Rolling, 12-month minimum
Organisations requiring the statutory role filled
Commercial basis: Monthly retainer
60 days
Organisations moving the role in-house
Commercial basis: Fixed fee
Every proposal states what is included, what is not, and what would trigger a change request. If the scope we recommend is smaller than the one you asked for, we will say so.
One implementation, cross-mapped. Each framework below links to its own obligations and control domains.
Specific answers about scope, timeline and what we will and will not do.
Ask a practitioner directly. First responses come from the person who would run your engagement, within one business day.
Ask a questionExecutive security leadership, sized to what you actually need.
A senior security leader embedded in your executive team — owning strategy, budget, board reporting and incident command — at a fraction of a full-time hire.
Explore capabilityTechnology strategy that a board can fund with confidence.
Senior IT leadership for organisations that need architecture, vendor and investment decisions made well — with trust and resilience designed in from the start.
Explore capabilityCombining capabilities reduces cost — the second framework typically lands at about half the price of the first.