DPDP Act 2023 — Breach Response

Data Breach Advisory

A data breach is one of the most legally and reputationally damaging events a business can face. Under the DPDP Act 2023, you have strict notification obligations — and the clock starts ticking the moment a breach occurs. We provide expert advisory for breach prevention, preparedness, and live incident response — protecting your business before, during, and after a breach.

72 hrs
Board Notification Window
₹250 Cr
Max Penalty for Breach
24/7
Emergency Response
3 Phases
Before, During & After
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The Law

What the DPDP Act 2023 Requires When a Breach Occurs

The Digital Personal Data Protection Act 2023 imposes strict mandatory obligations on every Data Fiduciary when a personal data breach occurs. Failure to comply — even if the breach itself was accidental — attracts separate, additional penalties on top of any liability for the breach. Most businesses have no idea what these obligations are until it is too late.

⏱️ Your Legal Obligations — Starting the Moment a Breach is Detected

Hour 1
Contain & Assess
Stop the breach from spreading. Identify what data was affected, how many individuals, and what type of data.
24 hrs
Internal Escalation
Alert leadership, legal counsel, and your DPO or privacy team. Begin documentation of the incident.
72 hrs
Board Notification
Mandatory notification to the Data Protection Board of India with specified details of the breach.
ASAP
Notify Affected Users
All affected Data Principals must be individually notified with specific information about the breach and remedial steps.

No Incident Response Plan

Most businesses discover they have no breach response plan only when a breach actually happens. With a 72-hour notification deadline, improvising under pressure leads to missed deadlines, incomplete notifications, and additional penalties on top of the breach itself.

Delayed or Wrong Notifications

Notifying the Board late, notifying the wrong authority, or sending incomplete notifications triggers separate penalty proceedings. The notification itself must contain specific mandatory information — getting it wrong is a second violation.

Concealing a Breach

Attempting to cover up or delay reporting a breach — hoping it won't be discovered — carries the maximum penalty under the DPDP Act and can expose individual directors and officers to personal liability.

No Post-Breach Documentation

After a breach, the Board may investigate and require evidence of your response. Without proper documentation of every step taken, you cannot demonstrate compliance — even if you did everything right — making defence nearly impossible.

Complete Coverage

Our Data Breach Advisory — 3 Phases

We support your business at every stage — building resilience before a breach, guiding your response during one, and protecting you from regulatory and legal consequences after.

Phase 1 — Before a Breach

Breach Preparedness & Prevention

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Incident Response Plan

Custom written IRP — detection protocols, escalation chains, roles and responsibilities, notification checklists, and decision trees for every breach scenario.

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Breach Risk Assessment

Identification of your highest-risk data stores, access points, and vendor relationships — prioritising where a breach is most likely to occur and what would cause the most harm.

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Tabletop Breach Simulation

A live simulation exercise walking your team through a realistic breach scenario — testing your response, identifying gaps in your IRP, and building team confidence before a real incident.

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Notification Templates

Pre-drafted notification templates for the Data Protection Board and for affected users — ready to be completed and dispatched within hours of a breach, not drafted under panic.

Phase 2 — During a Breach

Live Incident Response Support

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Emergency Legal Advice

24/7 emergency legal advisory from our advocates — guiding every decision from the moment you discover a breach, ensuring every action protects your legal position.

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Breach Severity Assessment

Rapid legal assessment of the breach scope — what data was affected, risk to individuals, notification thresholds, and whether the incident triggers mandatory reporting obligations.

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Board Notification Drafting

Drafting and reviewing the mandatory notification to the Data Protection Board — ensuring it contains all required information, is accurate, and is submitted within the 72-hour window.

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User Notification Management

Drafting individual user breach notifications — with accurate information, appropriate tone, practical remedial advice for affected individuals, and legally protective language for your business.

Phase 3 — After a Breach

Post-Breach Recovery & Regulatory Defence

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Regulatory Investigation Defence

If the Data Protection Board initiates an inquiry, we represent your organisation — preparing your response, compiling evidence of compliance actions, and advocating for proportionate remedies.

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Incident Documentation

Comprehensive documentation of the entire incident and response — timeline, actions taken, notifications sent, remediation steps — creating the audit trail you need to defend against penalty proceedings.

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Root Cause & Remediation

Post-breach review to identify the root cause, implement fixes, and strengthen controls — demonstrating proactive remediation to the Board, which is a significant mitigating factor in penalty decisions.

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Stakeholder Communications

Guidance on communicating with clients, partners, investors, and media about the breach — protecting your reputation and business relationships while staying within legal boundaries.

Legal Requirements

What a DPDP Breach Notification Must Contain

An incomplete notification is treated as a failure to notify. Every notification — to the Board and to affected users — must include all mandatory elements.

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Nature of the Breach

Precise description of what happened — unauthorised access, accidental disclosure, ransomware, insider threat — with known or estimated date and time of occurrence and discovery.

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Categories & Number Affected

Categories of personal data affected (names, financial data, health records, etc.) and the approximate number of Data Principals whose data was compromised.

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Likely Consequences

Assessment of likely harm to affected individuals — financial loss, identity theft risk, reputational damage, physical harm — and the severity of the risk posed by the breach.

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Remedial Measures Taken

Steps taken or proposed to address the breach — containment actions, system fixes, access revocations, and measures to prevent recurrence — demonstrating active remediation.

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Contact Details

Name and contact information of the Grievance Officer or data protection point of contact — so the Board and affected individuals have a direct line for follow-up queries.

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Advice to Affected Users

Practical steps affected individuals should take to protect themselves — changing passwords, monitoring bank accounts, placing fraud alerts — demonstrating your duty of care beyond just notification.

How We Work

Engaging Our Breach Advisory Services

1

Preparedness Engagement (Pre-Breach)

Engage us before any breach occurs. We conduct a breach risk assessment, draft your Incident Response Plan, create notification templates, and run a tabletop simulation. This is the most valuable investment — preparation costs a fraction of what a live breach response costs, and a documented IRP is a mitigating factor if a breach later occurs.

Proactive Best value
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Emergency Response (Active Breach)

If you are currently experiencing a breach — call us immediately. We provide emergency legal advice within the hour, guide your response in real time, draft your Board notification before the 72-hour deadline, and manage all communications to affected users. Available 24/7 for live incidents.

24/7 emergency line Response within 1 hour

Post-Breach Recovery

If a breach has already occurred, engage us for regulatory defence, incident documentation, root cause remediation, and stakeholder communications. Even late engagement can significantly reduce penalty exposure by demonstrating good-faith remediation efforts to the Data Protection Board.

Penalty mitigation Regulatory defence

Why Choose Vakil Help Desk for Breach Advisory?

1-Hour Emergency Response

When a breach occurs, every minute matters. Our advocates are available 24/7 and respond to breach emergencies within one hour — guiding your first critical decisions before mistakes are made.

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Advocate + IT Expert Team

Breach response requires both legal and technical expertise simultaneously. Our team includes cyber law advocates and IT specialists — handling the legal and technical dimensions of your response together.

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DPDP & IT Act Expertise

Deep knowledge of both the DPDP Act 2023 and IT Act 2000 breach provisions — ensuring your response satisfies all applicable Indian legal requirements simultaneously.

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Penalty Mitigation Focus

Every action we guide you to take is designed not just for compliance but to build the strongest possible case for penalty mitigation — demonstrating good faith, swift response, and proactive remediation.

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Privileged Communication

All communications with our advocates regarding the breach are protected by legal professional privilege — meaning your candid disclosures to us cannot be compelled as evidence in regulatory proceedings.

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Retainer Option Available

For businesses with significant data exposure, we offer a breach response retainer — ensuring our team is on standby for your organisation with guaranteed response times and pre-negotiated rates.

Don't Wait for a Breach to Find Out You're Unprepared

The best time to build your breach response capability is before you need it. Engage us today to prepare your Incident Response Plan, train your team, and ensure you can meet your 72-hour notification obligation without panic.

⚡ Build My Breach Response Plan 🚨 Report an Active Breach

For live breach emergencies — WhatsApp us immediately for the fastest response.

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