Data Privacy Practice
A Methodology for Enduring Privacy Governance
Developed through a decade of cross border regulatory counsel across GDPR, PDPL, and DPDPA jurisdictions.
The VIBE Methodology
A structured governance model developed through extensive implementation across regulated industries. Each pillar addresses distinct compliance requirements while maintaining operational integration.
Legal Design Thinking orchestrates the four pillars of Vibe Data Privacy™ — translating complex regulatory mandates into actionable, human centred compliance frameworks that organisations can implement with confidence.
The VIBE framework represents our structured approach to data protection compliance. Built upon practical implementation experience across regulatory environments, it delivers measurable outcomes for organisations navigating complex privacy obligations.
Four interconnected disciplines — Verification, Implementation, Benchmarking, and Enforcement — provide the foundation for sustainable privacy programmes that withstand regulatory scrutiny.
Verification
Rigorous forensic audit of existing data lifecycles, identifying shadow PII and unverified legacy data.
Implementation
Architecting the technical layer for Privacy-by-Design. Integrating cryptographic consent artifacts into APIs.
Benchmarking
Continuous mapping of Indian DPDPA mandates against GDPR, CCPA, and GCC PDPL standards for MNC alignment.
Enforcement
Establishing the statutory grievance redressal nexus and defending against Board-level adjudications.
Penalty Threshold
₹250 Cr
Maximum under Section 33
Breach Notification
72 Hours
Rule 8 Requirement
Child Definition
18 Years
Section 9 Threshold
CERT-In Window
6 Hours
Cyber Incident Reporting
The Evidence Imperative
DPDPA signifies a fundamental shift: regulators will expect verifiable answers. While consent initiates data processing, evidence sustains compliance. Evidence reflects governance in action, not just intention on paper.
Controls
Technical and organisational measures designed to prevent misuse of data
Evidence Logs
Time-stamped, tamper-proof records demonstrating that controls were effective
Audit Readiness
The capability to retrieve and explain logs within a 72-hour timeframe
Liability Reduction
Evidence-backed decisions that mitigate penalties and disputes
Critical Evidence Categories
The Mindset Shift
Vibe Data Privacy™ transforms how organisations approach data protection—from reactive compliance to proactive, evidence-driven governance.
Consent as static checkbox
Consent as provable, real-time user journey
Every interaction logged as evidence of informed choice and ongoing intent
Compliance as IT burden
Compliance as C-Suite imperative
Proactive logging of controls and risk mitigation to prevent personal liability
DPO as optional advisor
DPO as legally empowered guardian
Actions and audit trails serve as vital, verifiable evidence in regulatory challenges
Incident response as reactive cleanup
Incident response as forensic readiness program
Every preparatory and response action immutably logged as legally defensible evidence
Data mapping as periodic documentation
Data mapping as always-on fingerprinting ledger
Immutably records complete lineage, access, processing, and lifecycle of every byte
The DPO Operating System
Six integrated layers that transform privacy compliance from annual audit to continuous, operational excellence.
Privacy Intelligence Layer
Real-time visibility into privacy posture
The KYD Principles
Effective data governance requires understanding data comprehensively—not just mechanically cataloguing it through automated tools.
Know Your Data
Understanding what data is held across systems
Know Your Purpose
Understanding why data is held and processed
Know Your Process
Understanding how data flows through operations
Know Your Privacy Policy
Understanding organisational privacy commitments
"DPDPA compliance is about traceability on demand. If your data truth takes time to assemble, it is not properly governed."
— Vibe Data Privacy™ Principle
Questions Regulators Will Ask
Under evidence-based compliance, organisations must provide verifiable answers—not policy references—to these fundamental queries.
How was consent captured?
Timestamp, method, notice version, affirmative action
How was consent withdrawn?
Withdrawal mechanism parity, processing cessation proof
How was child verification performed?
Age-gating method, parental consent verification
How was unlawful data reuse prevented?
Purpose limitation logs, access controls
How was data deleted?
Deletion requests, execution confirmation, retention exceptions
How was breach detected and escalated?
Detection timestamp, assessment, notification proof
You may connect with our team to discuss how the VIBE methodology can be adapted to your organisation's specific regulatory requirements and operational context.
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