Data Privacy Manager / Senior Manager

Job Description

1. DPDPA Implementation Strategy (The "From Scratch" Build)

• Gap Analysis: Conduct a comprehensive organization-wide gap analysis against DPDPA 2023 requirements and existing data practices.

• Data Mapping ROPA: Lead the discovery phase to create a dynamic Record of Processing Activities (ROPA). Map data lifecycles across all business verticals (Demat, PAN, e-Governance services).

• Policy Architecture: Draft and finalize internal Privacy Policies, Data Retention Policies, and Data Breach Response procedures tailored to the new Act.

2. Consent Architecture Rights Management

• Consent Management: Design the technical and legal workflow for obtaining "Verifiable Consent." Collaborate with IT to integrate with Consent Managers as defined in the Act.

• Notice Management: Redraft privacy notices (Itemised Notice) to ensure they are available in English and 22 scheduled Indian languages as mandated.

• Grievance Redressal: Set up the "Consent Withdrawal" and "Grievance Redressal" mechanisms for Data Principals (investors/clients) ensuring strict SLA adherence.

3. Significant Data Fiduciary (SDF) Obligations

• DPIA: Establish a framework for and conduct periodic Data Protection Impact Assessments (DPIAs) for high-risk processing activities.

• Audit Readiness: Act as the point of contact for the Independent Data Auditor (IDA) and ensure readiness for periodic privacy audits.

4. Vendor Third-Party Risk Management

• Review and renegotiate contracts with all Data Processors to ensure flow-down clauses regarding liability and security safeguards are legally binding under the new Act.

5. Training Culture

• Drive the "Privacy Culture" change. Conduct role-based training for employees, specifically targeting IT, Operations, and Customer Support teams regarding their obligations under DPDPA.

Required Skills