Every Data Principal has the right to have grievances addressed. This is not a suggestion. It is a statutory requirement. You must designate a point of contact, establish a process, and respond within prescribed timelines.
The Grievance Officer
Rule 3 requires that your privacy notice include details of the person who will handle grievances. This person must be designated, contactable, and empowered to address concerns. A generic email address without someone accountable behind it is insufficient.
Scope of Grievances
Data Principals may raise grievances about any aspect of your data processing. Concerns about consent. Questions about data accuracy. Requests for erasure. Complaints about security. Your policy must accommodate the full range of potential concerns.
- Consent-related concerns
- Data accuracy disputes
- Rights exercise requests
- Security and breach concerns
- General compliance questions
Response Timelines
Rule 8 provides 90 days to respond to Data Principal requests. Grievances should be acknowledged promptly and resolved within this window. Complex matters may take longer to investigate, but communication should be ongoing.
Escalation to the Board
If a Data Principal is unsatisfied with your response, they may escalate to the Data Protection Board of India. Your policy should acknowledge this right while working to resolve matters before escalation becomes necessary.
Essential Clauses
Grievance Officer Details
Rule 3(1)(d)Name, designation, and contact information
Submission Methods
Rule 8How grievances can be submitted
Acknowledgment Timeline
Rule 8When the complainant will hear back initially
Resolution Timeline
Rule 8Target timeframe for resolution
Escalation Path
Section 13Internal escalation before Board referral
Board Referral Right
Section 13Data Principal right to escalate to DPBI
Implementation Steps
Designate grievance officer with appropriate authority
Establish dedicated grievance intake channel
Create acknowledgment and response templates
Build tracking system with deadline monitoring
Train grievance officer on DPDPA requirements
Establish internal escalation for complex matters
Document all grievances and resolutions
Analyze patterns to identify systemic issues
Frequently Asked Questions
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