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DPDP 3.2.3 : DPDP and Cloud – Case Study – The Erasure Request That Broke Three Clouds at Once

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Suresh runs the technology operations of a growing e-commerce company in Chennai. Two lakh registered customers. Three cloud vendors — one handles transactions and payments, one runs the analytics and recommendation engine, and one powers the customer support chatbot.

Each vendor has a copy of customer personal data. Some overlap. Some don’t. Suresh has never mapped exactly which data lives where.

One afternoon, a customer sends a formal email invoking her right to erasure under the DPDP Act. She has deleted her account. She wants confirmation that all her personal data has been erased.

Suresh opens his systems. He can delete her record from the primary database. He can see her in the analytics platform. He thinks she might be in the support chatbot’s conversation history. He is not sure whether the payment processor retains her card data or whether the analytics engine has derived any insights about her that are stored independently.

He has 48 hours before he must confirm erasure. He does not know where to start.

The multi-cloud erasure problem under DPDP

Section 8(7)(b) of the DPDP Act, 2023 creates the cascade obligation: when erasure is triggered — whether by purpose completion, consent withdrawal, or Data Principal request under Section 12 — the Data Fiduciary must erase the personal data and cause its Data Processors to erase the personal data made available to them.

The word “cause” is important. The obligation is not to request. It is to cause — to ensure that erasure actually occurs across every downstream processor. Suresh cannot discharge this obligation by sending an email to three vendors and hoping they comply. He must have a contractual mechanism — and a technical verification mechanism — that confirms the data has been erased.

IS Audit Module 6 identifies multi-tenancy as a specific cloud privacy risk: in a shared cloud environment, data from different customers may be commingled, creating scenarios where erasure of one customer’s data requires careful isolation to avoid affecting other tenants’ data — and equally, to ensure complete deletion rather than merely marking a record as inactive.

The Data Processor contract that Suresh does not have

Rule 6(1)(f) of the DPDP Rules requires the contract between the Data Fiduciary and every Data Processor to include appropriate provisions for taking reasonable security safeguards — which, by extension of the Act’s overall framework, includes the ability to execute erasure on instruction.

Suresh’s three vendor agreements are standard subscription contracts. None of them include a clause that obligates the vendor to erase personal data on a specific Data Principal’s request within a specified timeframe. None of them include an API endpoint for automated erasure triggering. None of them require the vendor to confirm deletion with an audit record.

Without these contractual provisions, Suresh’s erasure obligation is practically unenforceable against his own vendors. He is accountable to the Data Principal — and he has no mechanism to discharge that accountability.

The technology architecture Suresh needed to build

A DPDP-compliant multi-cloud environment for a Data Fiduciary requires a data mapping inventory — a live register of which personal data categories sit with which Data Processor, updated as the technology stack evolves. Without this map, Suresh cannot identify all the locations that must be cleared when an erasure request arrives.

It requires Data Processor contracts that include specific erasure API or webhook obligations — technical hooks that allow the Data Fiduciary’s erasure workflow to send a deletion instruction directly to each processor’s system and receive a timestamped confirmation.

It requires an erasure orchestration layer — a workflow engine that receives the Data Principal’s erasure request, identifies every processor in the data map holding that individual’s data, dispatches deletion instructions simultaneously, collects confirmations, and generates an audit trail of the completed erasure.

IS Audit Module 6 identifies cloud migration risks including insufficient planning and processes as a leading cause of cloud security failures. Suresh’s situation is exactly this: the cloud architecture was expanded incrementally without a corresponding expansion of data governance. Each new vendor added a compliance obligation that was never mapped, never contracted for, and never operationalised.

What the customer actually has the right to

Under Section 12 of the DPDP Act, Suresh’s customer has the right to erasure of her personal data unless retention is required by law. Under Section 11, she has the right to know the identities of all Data Processors with whom her data was shared. She does not need to know that Suresh has three cloud vendors — but she is legally entitled to find out.

Under Rule 8(3), personal data and processing logs must be retained for at least one year — so complete immediate erasure across all systems is not always possible. But the customer’s primary profile data, her transaction history shared with analytics, and her support conversations must be erased on schedule, with the one-year minimum applying only to logs.

The distinction between what must be retained for compliance and what must be erased on request requires data classification — another element of governance Suresh has not yet built.

The cloud is not one system. Neither is the compliance obligation.

Every Data Processor your organisation engages creates a branch of the same compliance obligation. Consent. Security safeguards. Breach notification. Erasure on instruction. Data Principal rights access. Each branch must be contractually formalised, technically implemented, and operationally testable.

The cloud makes personal data processing faster, cheaper, and more scalable. The DPDP Act ensures that those efficiencies do not come at the cost of Data Principal rights — regardless of how many cloud vendors the efficiency requires.

Sources: DPDP Act 2023 | ICAI IS Audit 3.0 Course

Disclaimer

The contents of this post are intended for general awareness and informational purposes only. They do not constitute legal opinion, professional advice, consultancy, statutory interpretation, or a recommendation to act in any particular manner.

The Digital Personal Data Protection Act, 2023, related rules, notifications, regulatory guidance and judicial interpretations may evolve from time to time. The applicability of the law may also vary depending on the facts, sector, nature of data processing, organisational role, contractual terms and compliance framework.

Readers should not rely solely on this post for making legal, business, HR, technology, data-processing or compliance decisions. Specific advice from a qualified legal, privacy, cybersecurity, governance or compliance professional should be obtained before acting on any matter discussed.

The author / publisher shall not be responsible for any loss, liability, claim, penalty or consequence arising from reliance on the contents of this post without independent professional advice.

Authors:
This article has been co-authored by CA. Sunil Elayadath and CA. Karthik Narayanan S, Partners of Karthik & Sunil, together with Mr. Dhanesh P. K., Designated Partner, DSK Sustainability Tech.

DPDP 3.2.3 : DPDP and Cloud – Case Study – The Erasure Request That Broke Three Clouds at Once

Cloud Dependency is No Longer Only an IT Procurement Matter; It is a Sovereignty, Economic Policy and National Security Matter

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Dutch Microsoft Issue: A Business Perspective for Indian Enterprises

A recent incident in the Netherlands has sent a quiet but unmistakable signal to boardrooms and policy corridors around the world — including in India. Microsoft reportedly shared documents containing the names of Dutch civil servants, who were working with Dutch regulators, with the United States House of Representatives. The documents included emails, meeting minutes and official invitations. Dutch authorities said they needed to investigate further before drawing conclusions.

For Indian businesses, the lesson is not about the Netherlands. It is about the nature of cloud dependency — and what it means when the infrastructure your enterprise runs on is ultimately governed by a foreign legal system.

1.  Data Residency vs. Data Sovereignty: A Critical Distinction

Many Indian companies believe they have addressed their data risk by choosing a cloud provider’s Mumbai or Hyderabad region. That belief is dangerously incomplete. There is a fundamental difference between two concepts that are often conflated:

ConceptWhat It Actually Means
Data ResidencyWhere the server physically sits. Your data may be stored in Mumbai, but the company that runs that server may be incorporated in the United States.
Data SovereigntyWho can legally compel access to that data — through whose courts, under whose laws, and through which administrative and technical controls.

The Netherlands’ own Court of Audit had already warned in January 2025 that the Dutch central government had entered cloud contracts without completing mandatory risk assessments for two-thirds of major cloud services reviewed. India must not make the same error.

2.  The U.S. CLOUD Act: What Every Indian Business Leader Should Know

Under U.S. federal law (18 U.S.C. § 2713), any U.S.-based provider of electronic communication or cloud computing services must preserve, back up, or disclose customer data within its possession, custody, or control — regardless of where that data is physically located. This is not a hypothetical risk. It is a statutory obligation.

This does not mean that a U.S. government official can browse your company’s data at will. The correct position is more nuanced: a U.S. cloud provider may be legally compelled, under appropriate legal process, to produce data it technically controls — even if that data is stored in a server in India.

For Indian enterprises, the practical question is straightforward: Does your cloud provider’s parent company have U.S. jurisdiction? If yes, U.S. lawful access risk exists regardless of which Indian region your data sits in.

3.  Can Indian Data Be Shared with a Foreign Government via an Indian Subsidiary?

This is a question increasingly being asked by Indian businesses that use global cloud platforms through locally-incorporated entities. The answer is: not automatically — but the risk is real, and it depends on how the system is architected.

An Indian subsidiary is a separate legal entity under Indian law. However, if the U.S. parent company or a U.S.-governed service provider has access to administrative controls, identity systems, support logs, telemetry, backup infrastructure, or encryption keys — a foreign legal demand may create real exposure for Indian data.

Practical scenarios Indian businesses must consider:

  • If you use Microsoft 365, Azure, AWS, or Google Cloud under a globally-managed service model, foreign lawful access risk exists — even for data stored in India.
  • If your data is stored in India but identity management, support, telemetry or backups are handled globally, local storage alone does not guarantee sovereignty.
  • If encryption keys are exclusively controlled by you or an Indian-governed entity, your exposure is materially reduced.
  • If your vendor’s Indian subsidiary operates with no parent-company access and no U.S.-controlled cloud layer, the risk is lower — but must be verified through contracts and audits.

4.  It Is Not Only a U.S. Issue — The Broader Principle

India should be careful not to frame this as a problem unique to American technology companies. Sovereign access laws exist in multiple jurisdictions:

  • The United Kingdom’s Investigatory Powers Act has extraterritorial features, with certain notices already being served on overseas operators.
  • Australia’s Assistance and Access Act gives agencies tools to require industry cooperation and access digital evidence.
  • China’s National Intelligence Law (Article 7) requires organisations and citizens to support, assist and cooperate with state intelligence work.

The principle, therefore, is universal: any foreign-controlled digital infrastructure may carry foreign sovereign access risk. Indian businesses need a framework grounded in this reality — not one that merely substitutes one foreign provider for another.

5.  Why This is Now an Economic and Business Competitiveness Issue

Data is no longer merely an operational input. It is a strategic economic asset. It drives AI models, credit scoring, health analytics, market intelligence, consumer behaviour mapping, financial surveillance, and supply chain optimisation.

When Indian enterprise data sits on foreign-controlled infrastructure, the business consequences are tangible:

  • Loss of bargaining power: Indian firms become dependent on foreign providers’ pricing, licensing, service continuity, and policy decisions.
  • Compliance cost escalation: DPDP Act obligations, sector-specific regulations (RBI, IRDAI, SEBI), and cross-border transfer requirements all add legal and operational overhead.
  • Innovation dependency: Indian AI and analytics capability built on foreign APIs and model ecosystems may be subject to unilateral access restrictions or commercial discontinuation.
  • Competitive intelligence exposure: Even anonymised or aggregated data, when processed on foreign infrastructure, can reveal patterns about Indian market behaviour, pricing, and institutional strategy.
  • Trade friction risk: Cross-border data restrictions can impede outsourcing, SaaS delivery, cloud migration, and global service contracts.

The European Union has already navigated this at scale. The Court of Justice of the European Union invalidated the EU–U.S. Privacy Shield in 2020, primarily over concerns about U.S. surveillance access. A new EU–U.S. Data Privacy Framework came into force in July 2023 — but the repeated litigation surrounding these arrangements demonstrates how economically consequential and legally fragile cross-border data flows can be. India should observe this experience and prepare its own frameworks proactively.

6.  Should Indian Businesses Push for Indian Sovereign Cloud?

Yes — but with an important qualification. A data centre located in India is not, by itself, a sovereign cloud. What India needs is not mere data residency but genuine digital sovereignty: Indian-owned infrastructure, Indian-law-governed operations, India-based administrators, India-controlled encryption keys, auditable sub-processor chains, and strong security standards.

India has already taken steps in this direction. MeitY has empanelled cloud service providers following Standardisation Testing and Quality Certification (STQC) Directorate audits against ISO 27001, ISO 27017, ISO 27018 and ISO 20000 standards. NIC functions as a government cloud provider while engaging private players through structured tender processes.

A tiered sovereign cloud policy — rather than a blanket localisation mandate — is the right direction:

Data CategoryRecommended Approach
Ordinary commercial dataGlobal cloud with DPDP compliance, robust contracts, security controls, and transfer impact assessments.
Financial, health, children’s data, public-sector databasesIndia-region storage mandated, stronger encryption, and auditable access logs.
Defence, law enforcement, judicial systems, core government identitySovereign cloud operated by Indian entities or government-controlled bodies with no foreign administrative access.
AI training datasets derived from Indian citizensSpecial rules on anonymisation, model training, onward transfer, and foreign access — to be developed as a priority.

7.  An Immediate Compliance Checklist for Indian Organisations

Indian businesses using foreign SaaS and cloud services should immediately review the following:

  • Data Map: What personal data is collected, where it is stored, and where it is processed.
  • Vendor Map: Cloud provider, SaaS provider, sub-processors, and support locations — including parent company jurisdiction.
  • Cross-Border Transfer Register: All instances where data moves outside India, with the legal basis for each transfer.
  • Processor Contracts: Agreements under Section 8 of the DPDP Act with all data processors.
  • Foreign Lawful Access Risk Assessment: Assess whether your vendor’s parent company is subject to U.S. CLOUD Act or equivalent foreign access laws.
  • Encryption and Key Management Policy: Ensure encryption keys are controlled by your organisation or an India-governed entity.
  • Breach Notification Readiness: Plans and timelines to comply with DPDP Act breach notification obligations.
  • Exit and Data Portability Plan: Ability to migrate data and operations if a vendor relationship ends.
  • Sectoral Law Review: Review obligations under RBI, IRDAI, SEBI, telecom, health, and government procurement rules.
  • Board-Level Data Sovereignty Policy: Governance-level oversight of data sovereignty decisions for sensitive datasets.

The Business Leadership Imperative

The Dutch–Microsoft episode is not a distant IT story. It is a warning signal for every Indian enterprise that has signed a cloud contract without fully understanding who ultimately controls its data — and under whose law.

India should not reject foreign cloud technology. That would compromise innovation and efficiency. But Indian business leaders must stop treating data infrastructure as purely a technology or procurement decision. It is simultaneously a legal risk, an economic policy choice, and a national security variable.

The real question — the one that every board, every CFO, and every CTO in India should now be asking — is not where is our data stored? but rather: who can legally, technically and operationally control our data when pressure comes?

Answering that question honestly is the first step towards genuine digital sovereignty.

Disclaimer / Author’s Note

The views and opinions expressed in this article are solely those of the author and are intended for general information and discussion purposes only. They do not constitute legal advice, professional opinion, or the official position of any organisation with which the author may be associated. Readers are advised to seek appropriate professional advice before acting on any matter discussed herein.

Author: CA.Sunil Elayadath | Partner | Karthik & Sunil |

Cloud Dependency is No Longer Only an IT Procurement Matter; It is a Sovereignty, Economic Policy and National Security Matter

DPDP 3.2.2 : DPDP and Cloud – Case Study 2 – The Payroll Data That Left India Without Anyone Noticing

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Ananya is the HR Manager of a mid-sized manufacturing firm in Pune. Three hundred employees. Payroll processed through a popular SaaS platform. Everything automated, everything on time.

One afternoon, a data privacy consultant visits for a routine review. She asks Ananya a simple question: “Where does your payroll platform store the data?”

Ananya checks the platform’s help documentation. Then its terms of service. Then calls their support line.

The answer comes back: servers in Singapore.

The salary details, bank account numbers, PAN numbers, and attendance records of all three hundred employees — sitting on servers outside India. No one in the organisation knew. No one had reviewed the contract for a data storage clause. No one had asked.

Why geography matters under DPDP

The Puttaswamy judgment  acknowledges that data protection challenges are not limited to data localisation but have become extra-territorial — cross-border transfers of personal data raise complex regulatory questions that different jurisdictions are grappling with simultaneously.

The DPDP Act, 2023 addresses this directly. Section 16(1) empowers the Central Government to restrict the transfer of personal data by a Data Fiduciary for processing to such countries or territories outside India as may be notified. When those notifications are issued — and they will be, particularly for sensitive personal data categories — Ananya’s payroll platform will be non-compliant from that moment unless the firm has reviewed its architecture.

The Puttaswamy judgment further notes that every transaction on a digital platform is linked with some form of sensitive personal information — user IDs, account numbers, PAN numbers, biometric details. Payroll data falls precisely into this category. It is not a dataset that can sit in an unreviewed offshore location without governance.

The Data Processor contract problem

Beyond the cross-border question, there is a more immediate compliance issue. Section 8(2) of the DPDP Act requires a Data Fiduciary to engage a Data Processor only under a valid contract. That contract must — under Rule 6(1)(f) — include appropriate provisions for taking reasonable security safeguards.

Ananya’s firm signed up to the SaaS platform’s standard subscription agreement. That agreement almost certainly does not specify: the security standards to which the vendor holds itself, the encryption requirements for payroll personal data at rest and in transit, the access control and log retention requirements that Rule 6(1)(b) and (c) mandate, or the breach notification timeline that allows the firm to meet its 72-hour Board reporting obligation.

A standard SaaS subscription is not a DPDP-compliant Data Processor contract. The firm is processing employee personal data through a vendor with whom it has no contractual security obligations that meet the Act’s requirements. That is a compliance gap — and it exists for every SaaS tool in the firm’s technology stack.

The employees’ rights and what the firm cannot currently honour

Ananya’s three hundred employees are Data Principals under the DPDP Act. Each has the right under Section 11 to access a summary of their personal data being processed and the identities of all Data Processors with whom it has been shared. If an employee asks — which they are legally entitled to do — Ananya’s firm must disclose that their salary and bank account data is stored on servers in Singapore by a named SaaS vendor.

Each employee also has the right under Section 12 to request correction of inaccurate data and eventually erasure when employment ends. The firm must be able to give the SaaS vendor a contractually binding erasure instruction and receive confirmed deletion. Without a Data Processor contract that specifies this obligation, the erasure right cannot be practically honoured.

The practical steps Ananya’s firm needs to take — now

Review every SaaS and cloud platform in the technology stack that processes employee or customer personal data, and document where each platform stores data geographically.

Negotiate or obtain Data Processor Addendums from each vendor — specifying security safeguards, breach notification timelines, data residency commitments, and erasure procedures aligned with DPDP requirements.

Monitor the Central Government’s notifications under Section 16 for data localisation requirements — and build an architecture that can respond to those requirements without a full platform migration.

Build an employee-facing disclosure — accessible via the HR portal — that identifies the Data Processors used and the data shared with each, so that the right to access under Section 11 can be immediately satisfied.

The question every HR and operations leader must ask today

Do you know where every piece of employee personal data in your organisation is physically stored? If you do not — the DPDP Act requires you to find out, document it, govern it contractually, and be prepared to disclose it to every employee who asks.

The data did not leave India without anyone noticing. Someone noticed. Just not in time to prevent it, and not yet in time to govern it.

Series 2, Episode 2 — Post 2 of 3 | DPDP Meets Emerging Technologies

Sources: DPDP Act 2023 (Sections 8(1), 8(2), 11, 12, 16(1)) | DPDP Rules 2025 (Rules 6(1)(b)(c)(f)) | ICAI IS Audit 3.0 Course Materials | Justice K.S. Puttaswamy (Retd.) vs Union of India (2018)

Disclaimer

The contents of this post are intended for general awareness and informational purposes only. They do not constitute legal opinion, professional advice, consultancy, statutory interpretation, or a recommendation to act in any particular manner.

The Digital Personal Data Protection Act, 2023, related rules, notifications, regulatory guidance and judicial interpretations may evolve from time to time. The applicability of the law may also vary depending on the facts, sector, nature of data processing, organisational role, contractual terms and compliance framework.

Readers should not rely solely on this post for making legal, business, HR, technology, data-processing or compliance decisions. Specific advice from a qualified legal, privacy, cybersecurity, governance or compliance professional should be obtained before acting on any matter discussed.

The author / publisher shall not be responsible for any loss, liability, claim, penalty or consequence arising from reliance on the contents of this post without independent professional advice.

Authors:
This article has been co-authored by CA. Sunil Elayadath and CA. Karthik Narayanan S, Partners of Karthik & Sunil, together with Mr. Dhanesh P. K., Designated Partner, DSK Sustainability Tech.

DPDP 3.2.2 : DPDP and Cloud – Case Study 2 – The Payroll Data That Left India Without Anyone Noticing

DPDP 3.2.1 : DPDP and Cloud – Case Study 1 – The Cloud Vendor’s Breach. The Founder’s Problem.

Karthik & Sunil, , , , , , , , , , Leave a comment

Vikram is 34 years old. He built a thriving edtech startup from his apartment in Bengaluru. Fifty thousand registered users. A small but dedicated team. And all of it running on a global cloud platform.

When he signed up, he ticked the terms of service. The data processing agreement was long. He didn’t read it. He assumed the cloud provider would handle security — that’s what the cloud is for, right?

One morning, Vikram receives an automated alert. His cloud provider has detected unusual access to a storage bucket containing the personal data of his users — names, email addresses, learning history, and payment records. The provider’s security team is investigating.

Vikram logs a support ticket with the cloud vendor and waits for them to resolve it.

He does not know that the DPDP Act has already placed the obligation firmly on him — and the 72-hour clock started the moment he became aware.

The accountability that does not transfer

Section 8(1) of the DPDP Act, 2023 is direct: a Data Fiduciary shall, irrespective of any agreement to the contrary, be responsible for complying with the provisions of this Act in respect of any processing undertaken by it or on its behalf by a Data Processor.

Vikram’s cloud provider is a Data Processor. The personal data in that storage bucket belongs to Vikram’s users — users who gave their consent to Vikram’s platform, not to a global cloud company. The fact that the breach occurred at the cloud provider’s infrastructure does not move the compliance obligation. It remains with Vikram.

Section 8(2) requires that a Data Fiduciary may engage a Data Processor only under a valid contract. That contract must include — under Rule 6(1)(f) — appropriate provisions for taking reasonable security safeguards. If Vikram’s data processing agreement did not specify encryption of personal data at rest, access controls, log retention, and breach notification timelines aligned with DPDP requirements — the contract itself is a compliance gap.

The 72-hour window and what it demands from Vikram

Under Rule 7(2) of the DPDP Rules, 2025, a Data Fiduciary must intimate the Data Protection Board within 72 hours of becoming aware of a personal data breach — with the nature, extent, timing, location, likely impact, root cause, remedial measures, and a report on notifications sent to affected Data Principals.

Vikram became aware when he received the alert. The 72-hour clock started at that moment. It does not restart when the cloud vendor completes its investigation. It does not pause while the support ticket is open. It started when Vikram knew.

IS Audit Module 6 of the ICAI IS Audit 3.0 Course identifies a cloud-specific privacy risk directly relevant here: cloud computing involves a greater dependency on third parties and increased transborder flow of personally identifiable information, creating greater magnitude of privacy risks. The breach Vikram is experiencing is exactly that risk manifesting — and DPDP requires him to have anticipated it contractually, technically, and procedurally.

What Vikram should have built before going live on cloud

A DPDP-compliant cloud deployment for a Data Fiduciary requires four things that Vikram did not have.

A valid data processing agreement that explicitly requires the cloud provider to implement encryption, access controls, logs, and breach notification to the Data Fiduciary within a timeframe that allows the Data Fiduciary to meet its own 72-hour Board reporting obligation.

Encryption of personal data at rest in every cloud storage bucket and database — so that even if access is unauthorised, the data retrieved is unreadable without the decryption key (Rule 6(1)(a)).

Access controls and logs on every cloud resource holding personal data — so that Vikram can determine, at the time of the breach, exactly which data was accessed, when, and by whom (Rule 6(1)(b) and (c)).

A documented incident response workflow that — from the moment of a breach alert — initiates Board notification preparation, Data Principal communication, and forensic log preservation simultaneously, not sequentially.

The cloud is not a compliance shortcut. It is a processing architecture that transfers operational convenience to a third party while retaining legal accountability with the Data Fiduciary.

The question every founder must answer before their next cloud migration

Does your data processing agreement with your cloud provider obligate them — in writing — to implement the security safeguards that Rule 6 of the DPDP Rules requires? Does it require them to notify you of a breach within a timeframe that lets you meet your 72-hour obligation? Does it permit you to audit their compliance?

If the answer is “our standard plan terms cover it” — read the terms again. Vikram had the same assumption.

Sources: DPDP Act 2023 (Sections 8(1), 8(2)) | DPDP Rules 2025 (Rules 6(1)(a)(b)(c)(f), 7(2)) | ICAI IS Audit 3.0 Course — Module 6 (Section 6.3.5 — Cloud Privacy and Security Risks)

Disclaimer

The contents of this post are intended for general awareness and informational purposes only. They do not constitute legal opinion, professional advice, consultancy, statutory interpretation, or a recommendation to act in any particular manner.

The Digital Personal Data Protection Act, 2023, related rules, notifications, regulatory guidance and judicial interpretations may evolve from time to time. The applicability of the law may also vary depending on the facts, sector, nature of data processing, organisational role, contractual terms and compliance framework.

Readers should not rely solely on this post for making legal, business, HR, technology, data-processing or compliance decisions. Specific advice from a qualified legal, privacy, cybersecurity, governance or compliance professional should be obtained before acting on any matter discussed.

The author / publisher shall not be responsible for any loss, liability, claim, penalty or consequence arising from reliance on the contents of this post without independent professional advice.

Authors:
This article has been co-authored by CA. Sunil Elayadath and CA. Karthik Narayanan S, Partners of Karthik & Sunil, together with Mr. Dhanesh P. K., Designated Partner, DSK Sustainability Tech.

DPDP 3.2.1 : DPDP and Cloud – Case Study 1 – The Cloud Vendor’s Breach. The Founder’s Problem.