Go fractional. You don’t need a full-time DPO hire.
Work directly with Nagaraja Bangalore Subbarao — a DPDPA lawyer, data privacy expert and Fractional DPO — for Fractional DPO, Virtual DPO, and Outsourced Data Protection Officer services. 18+ years of legal, governance, and compliance experience, including advisory engagements with EY, EY Law, Protiviti, Artefact, Infosys, and Fortune 500 organisations, applied to a practical, business-focused DPDPA programme.
Worked with professionals and organisations associated with EY · EY Law · Protiviti · Artefact · Infosys · Fortune 500 & regulated industries
Why Fractional, Why Now
Growth-stage organisations are increasingly stuck between two extremes — a policy template that no longer covers them, and a full-time DPO salary they aren’t ready to justify.
Headcount Gap
Most growth-stage companies are too far along for a policy template, but not yet large enough to justify a full-time DPO salary.
Regulatory Exposure
Fintech, healthtech, insurance, and consumer platforms handling Data Principal volumes are first in line for enforcement attention.
Board Assurance
A fractional DPO reports in directly — a named, accountable point of contact, not a vendor relationship buried in a procurement file.
Who This Is For
Many organisations have legal obligations under the DPDPA, 2023 but don’t yet need a full-time Data Protection Officer. A fractional DPO provides executive-level privacy leadership at a fraction of the cost, while ensuring ongoing governance, regulatory readiness, and operational compliance.
Growth-stage companies
Past the point where a policy template is enough, not yet at the headcount that justifies a full-time DPO.
Regulated, data-heavy sectors
Fintech, healthtech, insurance, and platforms handling Data Principal volumes that draw regulatory attention.
Boards needing assurance
Leadership wants a named, accountable person overseeing compliance — reporting in, not a vendor on retainer.
Ideal for
Four Clauses, One Retainer
The engagement is structured the way a retainer should be — defined obligations, not an open-ended advisory relationship.
Acting or support DPO services
Either as the named Data Protection Officer of record, or in direct support of an internal appointee who needs practitioner-level backing.
- Named point of accountability for the data protection function
- Direct support to an existing internal DPO appointee
- Defined hours per month, scaled to organisational complexity
- Escalation path agreed at engagement start, not improvised later
Ongoing compliance oversight and reporting
Compliance is monitored on a cadence, not revisited only when something breaks.
- Periodic compliance register review and update
- ROPA maintenance as processing activities change
- Board or leadership reporting on compliance posture
- Tracking of obligations not yet in force, ahead of deadlines
Regulator-facing support and advisory
If the Data Protection Board makes contact, you have a practitioner who has already mapped your exposure — not someone starting from zero.
- Drafting and review of regulator correspondence
- Breach notification readiness and response coordination
- Data Principal rights request handling within statutory windows
- Representation in advisory discussions with the Board
Internal stakeholder coordination
A DPO who only talks to legal misses half the job. This clause keeps Product, IT, and HR aligned to the same compliance baseline.
- Working sessions with Product, Engineering, and IT teams
- HR coordination on employee data handling and training
- Vendor and processor onboarding reviews
- Single point of contact across functions for privacy questions
What Does a Fractional DPO Do
Your organisation receives continuous privacy oversight across compliance, contracts, incidents, and people — not a one-off project handed to a junior consultant.
DPDPA Compliance Oversight
- Privacy governance framework
- Compliance monitoring
- Gap assessments
- Policy reviews
- Implementation roadmap
Data Protection Officer Duties
- Act as your external DPO
- Support an internal DPO
- Management reporting
- Board reporting
- Regulator communications
Privacy Compliance Management
- Privacy notices
- Consent management
- Data Processing Agreements
- Vendor privacy reviews · ROPA
- Data lifecycle governance, privacy audits
Data Breach Management
- Incident response
- Breach readiness
- Notification support
- Investigation coordination
- Documentation, lessons learned
Data Subject Rights Management
- Access requests
- Correction · erasure
- Nomination
- Consent withdrawal
- Grievance handling
Vendor & Third-Party Privacy
- Processor agreements
- Vendor risk assessments
- Due diligence
- Contract reviews
- Privacy obligations
Employee Privacy
- HR compliance
- Employee notices
- Training
- Internal awareness
- Privacy culture
The Cost Comparison Most Pitches Skip
A full-time DPO hire is the right call past a certain size. Before that point, the maths rarely favours it.
Full-time DPO hire
- Senior compliance salary, year-round
- Recruitment cycle of 3–6 months
- Single point of expertise, no bench
- Continuing education and certification costs
- Idle capacity in low-activity months
Fractional DPO retainer
- Engaged from week one, no hiring delay
- Practitioner with Big 4 and Fortune 500 exposure
- Scoped hours matched to actual workload
- Continuity even as internal teams change
- Scales up ahead of audits or regulatory contact
From Onboarding to Standing Oversight
A fractional DPO retainer is structured in phases — the first 30 days look different from month seven.
Choose the Model That Suits Your Organisation
Every model is personally led — engagements are never delegated to a junior bench.
Advisory
- Monthly consultation
- Privacy guidance
- Compliance reviews
Fractional / Acting DPO
- Monthly governance
- Board reporting
- Vendor reviews
- Privacy oversight
Virtual DPO
- Remote engagement
- Leadership meetings
- Policy reviews
- Compliance monitoring
Dedicated Retainer
- Priority support
- Unlimited advisory (agreed scope)
- Incident response
- Regulator support · training
From First-Time Compliance to Global Entry into India
Who needs a fractional DPO
Startups
Growing quickly but not ready for a full-time DPO.
Mid-sized businesses
Need structured privacy governance without expanding headcount.
Large organisations
Require specialist expertise to support internal legal and compliance teams.
Global companies entering India
Need DPDPA expertise from an Indian privacy professional who understands both the statute and local enforcement expectations.
Experience That Goes Beyond Documentation
Many consultants provide templates. A fractional DPO becomes part of your governance function.
- Practical implementation, not just paperwork
- Legal expertise grounded in the DPDPA statute
- Technology understanding across AI and data systems
- Board-level communication and reporting
- Regulatory readiness, not reactive scrambling
- Business-first approach, not box-ticking
- Direct engagement with senior leadership
- Hands-on implementation support throughout
Across Regulated and High-Growth Sectors
Industries served
Who You’re Retaining
Practitioner-led, not outsourced to a junior bench — 18+ years · Big 4 (EY, EY Law) · Protiviti · Infosys · Fortune 500
Nagaraja Bangalore Subbarao (Nagaraja B S)
What Clients Say
“Mapped our DPDPA exposure faster than any consultant we’d spoken to, and the recommendations were practical, not theoretical.”
“Having a named DPO who actually understands the statute, not just GDPR translated into Indian law, changed how our board thinks about compliance.”
“Our consent flows for minors and parental data were a genuine grey area until this engagement. We finally have a defensible position.”
“The breach notification protocol he built for us treats the zero-threshold requirement seriously — most advisors we’d spoken to still assumed a materiality test.”
“As a B2B vendor processing client data across sectors, our DPA templates needed to flex across very different risk profiles. This was handled cleanly.”
Before You Book a Call
Frequently asked questions
Book Your Free 30-Minute Consultation
Whether you’re preparing for DPDPA implementation, strengthening privacy governance, or looking for an experienced external DPO, work directly with Nagaraja Bangalore Subbarao. No obligation. No sales pressure. Just practical guidance from one of India’s experienced DPDPA practitioners.
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Digital Personal Data Protection Act, 2023: Law and Practice in India
First Edition, 2026 · Data Privacy Academy · ★★★★★ — the definitive practitioner’s reference on India’s DPDPA 2023, covering legislative intent, compliance obligations, data principal rights, enforcement, and practical implementation frameworks. Authored by Nagaraja Bangalore Subbarao, Advocate.