The conversation around DPDP has, so far, been dominated by summaries of the law and broad explanations of what it demands. What is missing is an honest discussion about the distance between planning and execution. Organisations are busy drafting policies and mapping flows. Yet, the real work begins only when those plans collide with the realities of product behaviour, legacy systems, scattered data, and evolving user expectations. This early phase reveals a truth that is often understated. Privacy posture re imagination is simple to describe in theory, yet extraordinarily demanding when translated into living systems that handle data every second of the day.
Head – Privacy Implementation (Privy)
IDfy
The first fault line lies in how consent is imagined. Strategy decks often assume that consent can be collected once, explained once, and applied everywhere. Real products do not work this way. A user moves through many journeys, with changing intentions and varying awareness of how their actions relate to data use. The law places responsibility on the firm to ensure clarity and alignment with purpose. The practical challenge lies in expressing intention in a way that remains meaningful across different moments in the user experience. This is not a sign that the law is unrealistic. It is a sign that firms need a more mature design language for user intention.
The next level of complexity lies in the space between revocation and effect. Withdrawing consent is an uncomplicated right on paper. The systems that must respond to it are anything but uncomplicated. Data often sits in queues, transfers, analytics tasks, and partner routines that run asynchronously. Stopping these flows instantly is technically impossible and operationally unsafe. Firms now face a fundamental question: how to honor a user request without introducing failure into the system. The answer will not come from policy wording. It will come from architecture decisions and workflow discipline.
Principal Product Manager,
Privy by IDfy
Purpose management presents a deeper challenge. The moment purpose becomes a controlling concept, everything about data handling must adjust. Many firms have long-lived data that has travelled without explicit purpose annotations, because earlier laws did not require that level of structure. Now the organisation must decide not just what ‘purpose’ means today, but also how to apply that understanding to data collected years ago. This is far more than a compliance request. It is a fundamental shift in how organisations think about the life of data.
Vendor relationships add another layer of complexity. Every modern digital journey depends on partners. These partners are no longer silent processors in the background. Under DPDP, they become shared custodians of user trust. The concern is not whether a vendor has signed an agreement. The problem is whether the organisation has real visibility into how that vendor handles data, and whether their systems are built with even a basic level of privacy resilience. This requires a more rigorous and ongoing form of oversight than most firms have previously maintained.
Deletion is another area where planning and reality rarely align. A request to remove data cannot be treated as a simple switch. Firms hold information that supports tax compliance, dispute resolution, service continuity, and fraud prevention. All of these involve obligations that extend beyond user preference. The tension between respecting user choice and maintaining lawful operation demands a structured internal view of data categories and retention responsibilities. Any firm that sees deletion as a single mechanical action is going to struggle the moment real cases begin to arrive.
These frictions do not indicate failure. They suggest that DPDP is pushing organisations toward a more disciplined relationship with data. The law expects clarity and control. Implementation requires new patterns in design, engineering, governance, and product architecture. The organisations that look at this moment with clarity rather than abstraction will define the next chapter of the industry. DPDP is not a regulatory hurdle. It is a long cycle shift in how firms think about identity, intention, and responsibility in a digital society. Those who build strong internal foundations now will set the reference standard for the next decade. The reward is not a certificate of compliance. The reward is a structural advantage in trust, product credibility, and long-term user loyalty.
This is an eighteen-month journey for most firms, maybe longer for those with deep legacy estates. It asks for patience, discipline, and a willingness to rethink what data stewardship actually means. It is a period that will test design clarity, technical maturity, and the seriousness with which organisations handle the idea of user trust. Those who succeed will not only meet the expectations of the present moment, but also those of the future. They will shape the norms that guide the coming decade of digital practice.
–Authored by Puja Deshpande, Head – Privacy Implementation (Privy) at IDfy, & Nikhil Jhanji, Senior Product Manager at IDfy
