India’s companies in data-intensive sectors have largely built the basic machinery for data privacy, but running it smoothly at scale remains a challenge, according to a new study by MIT Sloan Management Review India in collaboration with IDfy.
The findings are based on a survey of 78 senior leaders conducted between December 2025 and January 2026 and show that while privacy-by-design frameworks and consent management systems are now commonplace, those controls weaken when they have to operate across legacy technology, fragmented tooling, and high-volume data environments.
That execution gap shows up early in the software lifecycle. Privacy-by-design within product development is most commonly described as “managed” rather than “embedded,” indicating that while practices exist, they are not consistently integrated into engineering standards, design reviews, and release processes across organizations.
Core technical capabilities appear more mature. All respondents said fewer than 10% of their data-processing applications are unable to support granular, individual-level deletion without significant manual intervention, suggesting that the mechanics required to execute basic rights are largely present across enterprise application environments.
Operational consistency, however, remains uneven. While many organizations have defined channels to receive and log data subject requests, automation and coordination across systems and teams vary widely, limiting scalability as volumes increase.
Consent management illustrates this tension most clearly. Capturing consent is widespread, but applying it consistently downstream remains difficult, particularly as data moves across tools, functions, and business units, exposing gaps between governance intent and system-level enforcement.
These weaknesses become material as scale increases. Reliance on manual steps and partial automation can work at low volumes, but it becomes unreliable as request volumes rise, systems proliferate, and regulatory scrutiny intensifies.
The study describes the gap between policy and practice as a shift from interpreting India’s Digital Personal Data Protection Act to executing it. High-level policies are no longer sufficient, and organizations increasingly need privacy controls embedded directly into technology systems and workflows.
The execution gaps identified in the study come into sharper focus as the government weighs reducing DPDP compliance timelines, potentially accelerating the pressure on companies to translate privacy frameworks into working systems.
Engineering emerges as a central bottleneck. Every respondent cited developer skills and adoption as a challenge in implementing privacy by design. Half also pointed to legacy systems, while an equal share cited fragmented tooling that does not integrate. The constraint, the study suggests, is not regulatory ambiguity but the difficulty of translating privacy requirements into system design and developer workflows.