Dependency Chain of the Programme
10-Phase Topological Delivery Roadmap: Register to Board Assurance
DPDP transformation cannot be executed in arbitrary parallel workstreams; it has strict mathematical dependencies. You cannot draft an accurate Section 5 Notice without knowing your Data Inventory and Purposes; you cannot build a Withdrawal Engine without a Consent Ledger; you cannot automate Deletion without mapping Processors and Backup architectures. This roadmap defines the critical path for enterprise delivery.
Dependency Chain of the Programme
Statutory Register
Anchor Act & Rules obligations (OBL-01..54)
Data Discovery & Inventory
Map schemas DS-001..010 & systems SYS-001..014
Purpose & Legal Basis
Assign s.6 vs s.7 legal bases to all data fields
Notice & Consent Gateway
Deploy multilingual notices & Consent Ledger (SYS-010)
Withdrawal & Retention Engine
State machine for purpose blocking & lawful holds
DSAR & Grievance Portal
Deploy Principal Portal (SYS-011) with SLA tracking
Dual-Clock Incident Manager
CERT-In 6h & DPDP Rule 7 response orchestration
Processor & Vendor DPA
Execute Section 8(2) contracts across all suppliers
SDF & DPIA Governance
Resident DPO, periodic audit & DPIA workflows
Board Assurance & Audit
Automated control testing & executive dashboard
๐ก Core Architectural Insights & Takeaways
Key technical and regulatory takeaways established by this architecture diagram.
๐ Statutory Grounding & Legal Perimeter
Primary Act and subordinate Rule provisions establishing the enforceable legal mandate for this diagram.
๐๏ธ Target Architecture & Impacted Systems
Enterprise nodes and store topologies impacted by this architectural pattern.
Public client boundary & untrusted intake surface for notices and consent capture
Domestic production database and primary system of record for loan servicing
Processor-operated messaging engine (ENT-004) gated by optional consent
Purpose-partitioned analytical warehouse staging operational reporting
Model training and algorithm development node gated against unconsented data
Internal employer database holding employee payroll and candidate records
Cold physical and scanned document store subject to statutory retention schedules
Offshore disaster recovery replica; isolated pending cross-border transfer checks
Third-party international BI environment (ENT-005); prohibited unconsented reuse
Immutable consent event store and Policy Decision Point issuing authority tokens
Self-service orchestration service for managing DSARs and grievance redressal
Security log repository preserving tamper-evident dual-clock audit trails
Integration pipeline tracking downstream processor instructions and acknowledgements
Isolated test environment ensuring recovered backups pass tombstone replay
โ๏ธ Associated Operational Controls
Control Master Matrix obligations enforcing the standards illustrated in this infographic.
๐ ๏ธ Implementation Guidance & Traps
Recommended technical sequencing and operational failure modes to avoid.
Recommended Implementation Sequence
- Establish a PMO tracking dependencies using this 10-phase sequence.
- Lock down Data Inventory before finalizing notice text.
- Run quarterly readiness checkpoints against the transformation roadmap.
Enterprise Traps & Failure Modes
- โ ๏ธ Buying a consent tool before understanding underlying backend data flows.
- โ ๏ธ Treating legal DPA updates as separate from technical processor deletion integrations.
๐ Verifiable Evidence Artifacts Vault
Required evidentiary workpapers for regulatory inspections and SDF audits.