Privacy · Data governance · AI advisory +91 97162 99280Mohit.gupta@qanalyx.com
Privacy · Data governance · AI advisory

Where the law meets the architecture.

Qanalyx advises Indian organisations on privacy, data governance and AI. We read the DPDP Act and the IT Act, and we read your systems, so every recommendation holds up in law and can be built in practice.

Illustration: a classical building joined by a brass line to a stack of layered data platforms
Two lenses, one opinion

Legal advice needs systems knowledge. Technical controls need a legal basis.

We work with both in the same room, so a finding names the provision it rests on and the control that satisfies it.

Legal lens

What the law asks

  • Which obligation applies, to whom, and from when
  • What counts as valid notice, consent and lawful use
  • What a contract with a processor or AI vendor must say
  • What evidence a regulator, auditor or court will expect
Technical lens

What the systems must do

  • Where personal data sits and how it moves
  • How consent, withdrawal and erasure work in each system
  • What is logged, who can see it and how long it is kept
  • How an AI system is tested, supervised and changed
Perspective

The Rules are notified. The clock is running.

The DPDP Rules were notified in November 2025 and phase in over up to eighteen months.

  1. November 2025DPDP Rules notified, with obligations phased in.
  2. About November 2026Consent manager provisions take effect, about twelve months after notification.
  3. About May 2027Remaining obligations on data processing take effect, about eighteen months after notification.
Up to ₹250 croreMaximum penalty under the Act’s Schedule, for failing to keep reasonable security safeguards against a personal data breach.

Timelines are as reported on notification of the Rules. Confirm dates and applicability for your organisation before acting. This summary is not legal advice.

Deliverables

See what an engagement produces.

Every engagement ends with documents and registers you keep. These are illustrative examples on synthetic data.

DPDP Readiness Assessment · Findings
Illustrative deliverable
SummaryFindingsEvidenceAction planBoard note
Readiness by area legal basis · score out of 100
AreaProvisionScore
Notice and consents.5–6
58
Rights and grievances.11–14
64
Processor oversights.8(2)
45
Security safeguardss.8(5)
71
Breach responses.8(6)
49
Children’s datas.9
38
Retention and erasures.8(7)
52
Overall
7 areas assessed
2 priority-one findings, 2 priority-two, 1 priority-three.
Scored against the Act and Rules, from interviews, documents and a walk-through of the systems.
Priority findings legal basis and effort side by side
#FindingBasisEffortPriority
1Consent text bundles marketing with service deliverys.6LowP1
2No documented escalation path for reporting a breach to the Boards.8(6)MediumP1
3Processor contracts lack deletion and sub-processor termss.8(2)MediumP2
4No verifiable-consent step for users who may be minorss.9HighP2
5Retention schedule exists for 3 of 11 systemss.8(7)MediumP3
Data Governance · Working Register
Illustrative deliverable
OverviewAssetsGlossaryStewardshipClassificationQualityPolicySharing
Registered data assets1,284▲ 38 this quarter
Stewardship coverage96%▲ 4 pts
Quality score92▲ 3 pts
Open issues7▼ 5 closed
Classification column level
ColumnDatasetClassTagControl
mobile_numberService requestsRestrictedPIIMasked
vendor_tax_idContract ledgerRestrictedPIITokenised
contract_valueContract ledgerConfidential—Role-based
account_open_dateAsset registerInternal—None
ward_codeCustomer masterPublic—None
Stewardship RACI
DomainStewardOwnerDPOIT
AssetsRACI
ContractsARCI
Citizen dataCARI
AnalyticsRAIC
Policy library 6 policies in force
ClassificationRetentionAccessSharingIncident handlingAnalytics data
Data Lake · Governance Review
Illustrative deliverable
CatalogueQualityLineageAccess logAI-ready
142BronzeRaw, as received
96SilverStandardised, matched
41GoldAnalysis-ready
Catalogue 8 of 279 datasets
DatasetLayerOwnerClassQuality
● Asset registerGoldEngineeringInternal
98
● Application formsSilverOperationsInternal
94
● Contract ledgerGoldProcurementConfidential
96
● Service requestsSilverCitizen servicesRestricted
89
◉ Customer masterGoldRevenueInternal
93
◉ Billing recordsSilverUtilitiesInternal
91
● Event logsBronzeField ITInternal
78
◉ Document scansBronzeRecords officePublic
96
● Structured   ◉ Unstructured
Lineage Customer view
Source application
Bronze · raw records
Silver · standardised
Gold · condition index
Dashboard · API
Completeness 99Validity 96Uniqueness 98AI-ready
AI Use-case Register · CERT-In tiers
Illustrative deliverable
RegisterRisk tiersAssessmentsVendorsOversight
AI use cases17▲ 4 this quarter
Using personal data93 high risk
Tier 3 and above3independent audit due
Assessments pending52 overdue
Register 6 of 17 use cases
Use caseOwnerPersonal dataCERT-In tierLegal touchpointsStatus
Customer support assistantServiceYesTier 2DPDP s.5–6, s.8Assessed
Résumé screeningHRYesTier 3DPDP s.8; fairness reviewIn review
Contract summariserLegalYesTier 2DPDP s.8(5); confidentialityAssessed
Demand forecastingPlanningNoTier 1Model risk onlyAssessed
Credit pre-screeningLendingYesTier 3DPDP; RBI FREE-AI; CERT-InPending
Marketing copy generatorMarketingNoTier 1IT Rules labelling; IPAssessed
Assessment checklist Résumé screening
Lawful basis and noticeDone
Training and retrieval data provenanceDone
Bias and accuracy testingIn progress
Human review point definedDone
Vendor terms and data locationIn progress
Logging and change controlOpen
Each use case is assessed on the same legal and technical checklist before it is approved.
Processor Register · Oversight
Illustrative deliverable
RegisterAgreementsAssessmentsSub-processorsExit and deletion
Processors24▲ 2 this quarter
Agreements in force213 to fix
Reviews due in 30 days4owners notified
Transfers outside India3basis recorded
Register 5 of 24 processors
ProcessorServicePersonal dataAgreementNext reviewLocation
Cloud hosting providerHostingCustomers, staffIn force12 daysIndia
SMS gatewayNotificationsMobile numbersIn force41 daysIndia
Payroll vendorPayrollStaff, bank detailsRenewal due9 daysIndia
Survey toolFeedbackContact detailsNo agreement—Outside India
Support desk softwareTicketsCustomersIn force66 daysOutside India
Flags show where the contract, the data and the law do not yet line up.
How we work

Study first. Framework second. Technology last.

A documented study comes before any recommendation, so decisions stand up to audit.

STAGE 1

Study

Map systems and data flows, review contracts and policies, and build a risk register.

STAGE 2

Framework

Policies, standards and decision rights, with draft clauses for contracts.

STAGE 3

Specification

Requirements for tools and controls, based on confirmed gaps and neutral between vendors.

STAGE 4

Assurance

Periodic reviews, board reporting and support through audits.

Read about our approach

Illustration: a stack of documents, a standing document and a magnifying glass
Knowledge sharing

DPDPIndia.in: a free knowledge portal on the DPDP Act, cyber crime and public-sector data governance

Qanalyx helps manage DPDPIndia.in, a knowledge-sharing portal that explains the Act in plain language, follows the Rules and publishes a monthly briefing. It is free to read and needs no sign-up.

DPDP Act and Rules 2025Rights of data principalsGovt and PSU data governanceMonthly briefing
Contact us

Know where you stand before you buy anything.

An independent privacy and data gap study shows what you hold, what is exposed and what to do first.