The DPDP Rules are phasing in through 2026 and 2027. Most organisations are working towards full operational compliance by May 2027.

What this means for you

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Professional services and agencies

Service businesses hold other people's data as a by-product of doing the work. There is rarely a database at the centre of it. There is email, a drive, a few spreadsheets and a lot of WhatsApp.

The Act applies to every organisation that holds personal data. What reasonable looks like changes a great deal by sector, and this is what it changes to here.

The position

What makes this sector different

Agencies, consultancies, recruiters, accountancy practices, law firms and other professional businesses hold client records, candidate details, identity documents, signed contracts and years of correspondence. Much of it concerns people who are not your clients at all, such as your client's own customers or candidates you never placed.

Because there is no single system, there is usually no single answer to where anything is. That makes discovery the step that does the most work here, and it is almost always the first time anyone has written the full picture down.

Discovery

Where personal data usually sits

Drawn from engagements and from the questions that come up most often on first calls in this sector.

Professional services and agencies
SystemWhat it holdsWhat usually needs attention
Email and shared drivesClient records, proposals, identity documents, signed contractsFormer staff retain access, and nothing is ever deleted
WhatsAppClient conversations, documents clients sent, group coordinationBusiness data sits on personal phones with no record or control
CRM or spreadsheetLeads, enquiry forms, call notes, follow-up historyLeads collected years ago still contacted, with no basis recorded
Candidate or client filesData about people who are not your direct clientsNo notice was ever given to the people the data is about
Subcontractors and freelancersClient data handled by people outside your payrollContracts cover fees and delivery, and say nothing about data
HR and payrollEmployee records, bank details, identity proofs, attendanceNo retention rule, so leavers' records stay live indefinitely
Specific risks

What we look at first here

Client data on personal devices. Convenient during a deadline, invisible afterwards, and usually outside every control you have.

Offboarding that misses things. The laptop and the email account get handled. The shared drive, the WhatsApp group, the analytics dashboard and the client portal do not.

Data about people who never contacted you. Candidates, your client's customers, references. They have rights, and they were never told you hold anything.

Subcontractors without data terms. If a freelancer handles client data on your behalf, you answer for what happens to it.

Your own clients asking you about this. Increasingly common in tenders, and a clear answer wins work.

The engagement

Which steps carry the most weight

The full sequence is on the engagement page. In this sector, these three usually do the heavy lifting.

Priority

Discovery and mapping

The whole value of the engagement often sits here, because nobody has ever listed where client data actually lives.

Priority

Compliance Support

A notice for the people whose data you hold, data terms for subcontractor agreements, a retention rule that finally closes old matters, and an offboarding checklist that covers everything.

Priority

Training, assurance and close out

Behaviour change matters more than technology in this sector. Most of the risk is in habits, not systems.

If your clients are starting to ask how you handle their data, this engagement produces the answer as a by-product. The evidence pack is exactly what a procurement questionnaire asks for.

Other sectors

Not quite your business?

Every engagement is scoped to what you actually run, so none of these pages will match you exactly.

Start here

Thirty minutes, and you will know where you stand.

Tell us what your business runs on. We will tell you which gaps matter most, whether or not you engage us.