The dual role of modern SaaS platforms under DPDP
Most SaaS companies operate under a dual regulatory identity under India's DPDP Act:
- As a Data Fiduciary: You determine the purposes for your direct account holders, billing contacts, website visitors, marketing leads, and internal employees.
- As a Data Processor: When enterprise customers upload personal data into your software platform (e.g., HRMS records, CRM customer data, end-user support logs), your customer is the Data Fiduciary and your SaaS operates as a Data Processor under contract.
Failing to cleanly delineate these two roles in customer contracts, database architectures, and privacy notices creates severe commercial friction during enterprise procurement security reviews.
Key SaaS architectural challenges we address
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Multi-tenant database isolation & access control
Verifying logical and physical separation between tenant records, ensuring support engineers cannot access raw customer tenant databases without time-bound, logged authorization.
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Product telemetry, analytics & tracking scripts
Auditing product analytics tools (Mixpanel, PostHog, Segment, Google Analytics) to ensure personal identifiers (IP addresses, user email strings) are not inadvertently captured without consent or valid lawful basis.
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Subprocessor supply-chain governance
Enterprise buyers require prior notice before subprocessors are added to your infrastructure chain (e.g. AWS, SendGrid, Stripe). We structure subprocessor notification mechanisms and customer opt-out mechanisms.
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Tenant offboarding & automated data purging
Demonstrating verified data erasure when an enterprise customer terminates their subscription, including deletion across primary databases, search indexes, and backup snapshots.