The Roles and Responsibilities of Grievance Officers Under DPDP Act 2025, India

The enforcement of the Digital Personal Data Protection Act, 2023 (DPDP Act) and the DPDP Rules, 2025 has profoundly reshaped India’s approach to privacy and data governance. The law now places enforceable rights in the hands of individuals and imposes strict accountability on organisations. This shift has transformed the grievance officer under DPDP from a procedural contact point into a mission-critical compliance leader. The DPDP grievance officer role has become central to organisational trust, regulatory compliance, and operational integrity.

Also Read: The DPDP Compliance Checklist (2025): Step-by-Step Guide for Indian Businesses

Statutory Basis for the Grievance Officer Role Under DPDP

The DPDP Act requires every Data Fiduciary to appoint and publish the contact details of a Data Fiduciary Grievance Officer. This role must ensure that individuals can file grievances easily, receive timely responses, and understand how their rights are being fulfilled. Whether the Grievance Officer comes from legal, compliance, privacy, or information security, they must be competent and empowered to operationalise the statutory responsibilities assigned to them.

Also Read: Top 7 Data Privacy Impact Assessment Tools in India

Procedural Duties and Timelines Under the DPDP Rules, 2025

The Rules operationalise the law by establishing strict expectations for speed, accuracy, and documentation, making grievance handling a regulatory requirement, not an administrative formality.

1. Acknowledgment Requirements

Every grievance must be acknowledged promptly, typically within 24 to 72 hours, and the acknowledgment must include a tracking ID, point of contact, and estimated closure window. A grievance officer under DPDP must meet these timelines consistently to avoid escalation or scrutiny.

2. Timelines for Rights Fulfilment

Most Data Principal requests access, correction, deletion, consent withdrawal, or general grievances must be resolved within 7 working days, unless legally documented exceptions apply. Under the DPDP Rules, denials must reference specific legal grounds. For a Data Fiduciary Grievance Officer, compliance here is critical.

3. Escalation and Appeal Workflow

If a user is not satisfied with the response, they must have access to an internal appeal mechanism. If still unresolved, the matter may escalate to the Data Protection Board of India (DPB). The entire audit trail must be preserved for potential regulatory examination.

4. Documentation and Record-Keeping

Rules 6 and 12 emphasise that Grievance Officers must maintain:

• Logs of all grievances

• Acknowledgment and closure timestamps

• Internal communication trails

• Decision-making justifications

• Breach notifications and actions taken

These must be readily available to the DPB. This is a core expectation of the DPDP compliance officer in India.

Also Read: Top 9 Features in a Data Privacy Management Platform

5. Cooperation With the Data Protection Board

A GO must be prepared to:

• Present complete records

• Explain the workflow

• Demonstrate statutory compliance

• Support breach investigations

Failure to do so can increase the organisation’s liability.

6. Liability Exposure for DPDP Grievance Officers

While statutory penalties are primarily organisational, the grievance officer under DPDP still carries internal and reputational risk.

7. Organisational / Internal Liability

Organisations may hold Grievance Officers accountable for delays, poor documentation, mishandling of sensitive grievances, or failure to escalate issues such as data breaches.

Also Read: Penalties Under DPDP: Fines, Breach Scenarios, and How to Reduce

8. Exceptional Personal Liability

While rare, personal exposure can arise in cases of bad faith, concealment of breaches, unlawful processing, or willful negligence.

9. Reputational Consequences

Mishandled cases may reflect adversely on the individual, even without personal penalties.

Safeguards for Grievance Officers: Protecting Yourself

To operate safely and successfully in the DPDP grievance officer role, individuals should adopt proactive safeguards.

1. Maintain Comprehensive Documentation

Every action, follow-up, decision, and legal opinion must be recorded with timestamps.

2. Use Escalations Appropriately

Sensitive personal data, children’s data, cross-border data, and breach indicators must be escalated promptly.

3. Avoid Independent Legal Interpretation

Legal positions must be validated through the organisation’s legal or compliance teams.

4. Follow Approved SOPs and Rule-Based Workflows

Operating strictly within SOPs protects both the organisation and the Data Fiduciary Grievance Officer.

5. Formal Written Appointment & Clear Authority

Defined responsibilities, authority levels, KPIs, and escalation triggers are essential.

6. Mandatory Training & Capacity Building

The DPDP Rules expect Grievance Officers to understand data flows, internal systems, regulatory timelines, and functional dependencies.

Also Read: Top 5 Consent Management Platforms in India 2025

How Privy by IDfy Strengthens Grievance Redressal Under DPDP

The DPDP regime demands precision, speed, and system-driven governance. This is where Privy provides unmatched value. Privy’s Consent Governance Platform (CGP) elevates the capabilities of the grievance officer under DPDP and enables Data Fiduciaries to institutionalise compliant redressal practices.

Privy centralises all Data Principal requests for access, correction, deletion, consent withdrawal, and general DPDP grievances into a single intelligent dashboard. Automated acknowledgments ensure that grievance redressal under DPDP always meets statutory requirements. Privy’s audit-ready logs capture every action with cryptographic evidence, creating a defensible record for regulatory scrutiny.

For the DPDP compliance officer in India, Privy removes operational friction by automating timelines, building consistent templates, enforcing escalation rules, and unifying collaboration across legal, IT, security, HR, and operations. Because Privy integrates consent artifacts, PII mappings, and processor data, including cross-border processors, Grievance Officers gain clarity and speed in decision-making.

Most importantly, working within Privy’s structured, rule-driven workflows protects the Grievance Officers. Every step is time-stamped, auditable, and aligned with DPDP requirements, offering both operational efficiency and personal protection. Privy does not just support a function; it strengthens the organisation’s entire grievance redressal posture under the DPDP Act.

Conclusion

India’s privacy regulation has entered a new era, one defined by precision, accountability, and enforceable rights. The grievance officer under DPDP now sits at the heart of organisational compliance, responsible for upholding user rights and guiding the organisation through regulatory expectations. Empowering this role is no longer a choice; it is a necessity for operational resilience and regulatory defence.

With the right training, clear SOPs, and a robust technology platform like Privy, the DPDP grievance officer role becomes not just manageable but deeply impactful, advancing trust, transparency, and compliance excellence across the organisation.

Get in touch with us at shivani@idfy.com to take control over your data with India’s most trusted DPDP compliance platform. We will keep you updated on the latest developments regarding the DPDP rules and how they will impact your business. Stay glued to this space for more information on data, privacy, compliance, and all things DPDP.