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DPDPA readiness for BPO and ITES companies.

BPO and ITES companies mostly process personal data on behalf of their clients rather than deciding why it's collected — which changes the shape of DPDPA obligations, but doesn't remove them. Readiness work usually starts with getting that processor relationship properly documented, not assumed.

What personal data typically looks like here

Customer data processed on behalf of clients (calls, chats, tickets)Call recordings and screen-capture logsEmployee data for a large, often distributed workforceAccess credentials to client systems
A customer-support agent wearing a headset, mid-call on a support floor

Where this usually creates the most work

Processor obligations under a client's instructions

As a processor, your obligations flow from your contract with each client, not from an independent decision about how the data should be used. Those contracts are worth reviewing specifically for what they say about DPDPA, not just data security in general.

Understand the roles

Access across a large, often distributed workforce

A large agent workforce, sometimes across multiple sites or working from home, means personal data is visible to more people than a smaller team would need. Access controls and monitoring matter more here than almost anywhere else.

See how we handle access

Call recordings and logs as a data category of their own

Recorded calls and chat transcripts often contain more personal data than the ticket itself — names, account numbers, sometimes health or financial details mentioned in passing. Worth treating as a distinct category with its own retention and access rules.

Sub-processing when work is delegated further

Offshoring part of a client's process to another vendor, or another site, adds another link the client needs visibility into. Each one should be disclosed and documented, not just handled internally.

Other industries

Readiness work looks different depending on how your organisation uses personal data.

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