A founder running a logistics-tech company out of Hyderabad called me with a mix-up I hear often. “We already have a DPO,” he said. “Do we really need a separate Grievance Officer too? Feels like double work.”
It’s not double work. It’s a separate role with a separate purpose. Mixing the two up is one of the most common mistakes I see Indian businesses make.
Grievance Officer and DPO Aren’t the Same Thing
A Data Protection Officer usually handles the bigger compliance picture. They oversee how your organisation processes data, manage risk, and act as the point of contact with the Data Protection Board of India on larger matters. A Grievance Officer serves a narrower purpose. They exist for the individual, the customer or employee who has a complaint about their own personal data.
In a smaller company, one person might wear both hats. Even so, the DPDP Act still expects a clear grievance function, with its own visible contact point, no matter who runs it.
What a Grievance Officer Actually Does
This role gives your customers and users a direct channel to raise concerns. Maybe they want to correct inaccurate information. Maybe they’re asking why you collected certain data. Maybe they believe you never obtained proper consent in the first place.
The Grievance Officer receives these complaints, responds within a reasonable time, and resolves them before they escalate. Left unresolved, a complaint can turn into a formal case with the Data Protection Board.
Think of this role as your first line of defence. A well-handled grievance rarely becomes a regulatory complaint. A poorly handled one usually does — ignored emails, no clear process, no follow-up.
Who Needs to Appoint One
Every Significant Data Fiduciary under the DPDP Act must appoint a DPO, and that DPO typically also handles grievances. But smaller businesses need this too. Every data fiduciary must give data principals a way to reach out about their data, regardless of size.
In practice, this covers most businesses processing any meaningful volume of personal data — e-commerce platforms, fintech apps, ed-tech companies, healthcare startups. It’s not just for the large, high-risk players.
What This Role Requires in Practice
A visible, working contact point. Don’t bury this on page four of your website. Your privacy policy should clearly list how to reach the Grievance Officer — a dedicated email address, a contact form, or a phone number.
A real name or designation. Vague references to “our support team” won’t meet the requirement. Name a specific individual or role responsible for this function.
A response timeline. The DPDP Act expects reasonable turnaround. Set your own internal SLA, commonly 7 to 30 days depending on complexity, and actually track it.
A documented process. Log every complaint. Investigate it. Respond to the person. Record the outcome. Without documentation, you can’t prove compliance if the Data Protection Board asks.
Escalation awareness. If a data principal isn’t happy with the outcome, they can approach the Data Protection Board directly. Your internal process should resolve most cases well before that point.
A Common Mistake Worth Avoiding
I’ve reviewed several privacy policies where the “grievance officer” section looks copy-pasted from another company’s template. Sometimes the wrong name still sits there from whoever the template belonged to originally. This looks embarrassing, and it signals something worse to a regulator — that the compliance measure exists on paper only, not in practice.
Make sure the person you appoint actually knows about the role. They should understand how to handle an incoming complaint and check the inbox or channel where complaints arrive.
Getting the Grievance Function Right
This role rarely gets the attention that consent or DPO appointments do. Yet it’s often the first thing a frustrated customer interacts with, and the first thing regulators check after receiving a complaint. A functioning, well-documented process protects your business long before things escalate.
Not sure your current grievance handling setup would hold up? Book a free consultation and we’ll go through your current setup together.