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Data Principal Management

Privacy by Design, Scalable by Default​

The Data Principal Management Module in Open Source SAHAJ empowers Data Fiduciaries, DPOs, and privacy operations teams to securely manage both legacy and new Data Principals while maintaining strict privacy-by-design standards.

Key features include:

  • Adding Data Principals via multiple mediums (manual, CSV, API).
  • Privacy-by-design “data blind” storage — no unnecessary PII.
  • Secure transition of legacy data to consent-based data handling.
  • Unified view of activities, consent trails, and DPDPA-related actions.

Problem Statement​

Organizations need to manage vast and diverse Data Principal records to comply with the Digital Personal Data Protection Act (DPDPA). Common challenges include:

  • Fragmented Onboarding: Different channels for customer acquisition with inconsistent data capture.
  • Legacy Data Migration: Handling old customer records while meeting consent requirements.
  • Excessive PII Retention: Increased risk of breaches due to unnecessary personal information storage.
  • Visibility Gaps: Difficulty linking Data Principal activities, consents, and processing scopes in one place.

Without a structured system, organizations risk non-compliance, inefficiency, and loss of trust.

How the Module Helps​

FeatureBenefit
Multiple Import MethodsAdd Data Principals via manual entry, CSV upload, or APIs — supporting both small teams and large-scale operations.
Data Blind DesignStore unique identifiers instead of PII for new Data Principals, ensuring privacy by design.
Legacy Data TransitionCollect email or mobile only to send legacy notices; delete PII once consent is obtained.
Unified Activity DashboardSee data collected, processing scope, consent trail, DPAR, and compliance-relevant actions per Data Principal.
Compliance-ReadyDirectly aligns with DPDPA’s principles of data minimization, purpose limitation, and user rights.

Key Functionalities in Detail​

1. Adding Data Principals​

  • Manual Upload: For small-scale additions or corrections.
  • CSV Upload: Upload thousands of records at once with structured templates.
  • API Upload: Secure endpoints for bulk ingestion from CRM, ERP, or data warehouses.
  • Automatic Validation: Check for duplicates and ensure proper format before adding.

2. Privacy by Design for New Data Principals​

  • Assign a system-generated ID instead of storing personal identifiers.
  • Store only what’s needed for consent processing, eliminating unnecessary PII.
  • Enable complete anonymity until explicit user consent is granted.

3. Legacy Data Principal Migration​

  • Upload legacy customer data with email/mobile solely to send legacy consent notices.
  • On obtaining consent:
    • Replace PII with system-generated IDs.
    • Delete or anonymize the original PII instantly.
    • Gradually transition legacy data into a fully data blind system.
  • This staged approach minimizes disruption while moving toward full compliance.

4. Unified Data Principal Dashboard​

  • Data Overview: View each Data Principal’s consent status, processing scope, and data activities.
  • Consent Trail: See complete history of consent collection, updates, renewals, and withdrawals.
  • DPAR Tracking: Manage Data Principal Access Requests (DPAR) including access, correction, and erasure.
  • Activity Feed: Track grievances, notifications, and data processing events in real time.

5. Role-Based Access for Privacy Teams​

  • Allow DPOs, Compliance Teams, and Admins to access dashboards with Role-Based Access Control (RBAC).
  • Segregate duties to reduce risk and ensure principle of least privilege.
  • Audit every action taken by staff to demonstrate accountability.

Implementation Flow​

  1. Initial Setup:

    • Configure import settings (manual, CSV, or API).
    • Map organizational identifiers and processing purposes.

  2. Onboard Data Principals:

    • Add new Data Principals without PII.
    • Import legacy Data Principals with minimal identifiers to send notices.

  3. Consent Transition:

    • Send legacy notices automatically.
    • On consent collection, replace PII with anonymized IDs and purge unnecessary data.

  4. Operate & Monitor:

    • View each Data Principal’s consent history, DPAR, and processing scope in the dashboard.
    • Generate reports or exports for internal or regulatory needs.

Privacy & Compliance Features​

  • Absolute Data Blind Mode: No personal identifiers stored by default for new Data Principals.
  • Secure Transition of Legacy Data: Temporary retention of contact details only until consent workflows complete.
  • Immutable Consent Trail: Audit-ready logs showing every action tied to Data Principal records.
  • Role-Based Access Control: Limit who can view, modify, or export Data Principal data.
  • DPAR Integration: Track and fulfill access, correction, and erasure requests directly from the module.

Best Practices for Using the Module​

  • Use system-generated IDs as the default identifier for all new Data Principals.
  • Migrate legacy data gradually — collect consent first, then anonymize.
  • Regularly audit dashboard activities to ensure compliance.
  • Train privacy teams on viewing and managing Data Principal records without exposing PII.
  • Integrate with your Consent Management workflows for seamless operations.