Data Privacy Manager/ Senior Manager
Data Privacy Manager/ Senior Manager
BKC, Mumbai
Essential: LL.B / LL.M (specialization in Tech Law preferred)
OR
B.E./B.Tech/MBA with significant demonstrable experience in Privacy Program Management.
Desirable: Preferred Certifications: CIPP/E, CIPP/A, CIPM, or CIPT (IAPP).
Total Experience: 5–7 years in Compliance, Legal, or Information Security.
Core Privacy Experience: Minimum 4+ years dedicated to Data Privacy.
Implementation Experience: Must have hands-on experience implementing privacy frameworks (GDPR, ISO 27701, or SPDI Rules) from scratch.
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.
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