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Data Subject Requests (DSR) Module

What Is This Module For?

The DSR module helps you manage requests from individuals (Data Principals) exercising rights under the Digital Personal Data Protection Act, 2023 (DPDP Act) — rights to access, correct, erase, and nominate, as defined in Sections 11–14.

Which Law Requires This?

  • DPDP Act 2023, Section 11 — Right to access information about personal data processed.
  • DPDP Act 2023, Section 12 — Right to correction and erasure.
  • DPDP Act 2023, Section 13 — Right to grievance redressal.
  • DPDP Act 2023, Section 14 — Right of nomination.
  • DPDP Rules 2025, Rule 7 — Response within 30 days of verification; 7 days for urgent requests.
Penalty: Failure to respond within the statutory timeline can attract penalties up to ₹10,000 per instance under DPDP Act Section 25.

Who Should Use This Module?

The DPO or Legal/Compliance team — anyone responsible for responding to data subject rights requests.

Step-by-Step Guide

  1. Go to Data Subject Requests in the sidebar.
  2. View incoming requests — filter by type (Access, Correction, Erasure, Nomination) or status.
  3. Verify the requester — dcomply sends an OTP/link to the requester's email automatically.
  4. Assign the request to a team member. They receive an email notification.
  5. Process the request — record actions taken, upload supporting documents.
  6. Respond to the requester using built-in response templates. The system records the response date.
  7. Close the request — the audit log is automatically preserved for 3 years.

Common Mistakes to Avoid

  • Not documenting the response — Always record what action you took, not just that you responded.
  • Ignoring Nomination requests — Section 14 requires you to accept a Data Principal's nominee.
  • Missing the appeal window — Grievances under Section 13 must be responded to within 30 days.

Frequently Asked Questions

Q: Can we reject a DSR?
A: Yes, but only on specific grounds permitted by the DPDP Act (legal obligation, national security, etc.). Document the legal basis for rejection.

Q: How long do we keep DSR records?
A: DPDP Rules 2025 require a minimum 3-year audit log. dcomply retains these automatically.


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