Your go-to hub for Expert Insights,
Publications, and Resources on
data privacy and compliance

The year 2025 has witnessed a significant surge in high-impact data breaches across various sectors, from aviation and healthcare to financial services and public institutions. Among these, the recent data breach at Qantas Airways stands out as one of the most consequential, both in terms of its scale and the nature of the compromised data. For India, currently in the implementation phase of the Digital Personal Data Protection Act, 2023 (DPDPA), such global incidents offer valuable insights and reinforce the urgent need to operationalize privacy governance mechanisms with precision and foresight.

India’s Strategic Takeaways: Insights for a DPDPA-Aligned Ecosystem

As India continues to strengthen its digital regulatory infrastructure through the DPDPA, the data breach incidents serve as cautionary case studies. Below are five strategic areas where India can derive actionable lessons:

1. Third-Party Risk Management

Key Insight: A significant number of 2025 breaches such as those involving Qantas, Adidas, and McLaren Health originated from vulnerabilities in third-party relationships.

India's Imperative:

• Mandate Data Processing Agreements (DPAs) for all third-party engagements.
• Conduct periodic Third-Party Risk Assessments to evaluate compliance and data handling practices.
• Include DPDPA obligations contractually with processors and vendors to ensure accountability under Indian law.

2. Purpose Limitation and Data Minimization

Key Insight: Organizations continue to retain large volumes of personal data unnecessarily, significantly increasing breach impact when systems are compromised.

India's Imperative:

• Operationalize Section 4 of the DPDPA, which emphasizes purpose limitation and consent-based processing.
• Enforce data minimization principles and mandate automatic deletion of outdated or redundant data.
• Encourage privacy-by-design frameworks during product and service development.

3. Breach Notification Protocols

Key Insight: Delayed or non-transparent disclosures, as seen in several 2025 breaches, erode public trust and impair mitigation.

India's Imperative:

• Define explicit timelines for breach reporting to the Data Protection Board of India.
• Standardize templates for notifying both regulators and affected data principals in clear and non-technical language.
• Encourage proactive disclosure practices to ensure timely containment and legal compliance.

4. Access Control and Zero Trust Architecture

Key Insight: Many attacks were facilitated by compromised credentials and insufficient access segmentation.

India's Imperative:

• Promote adoption of Zero Trust Architecture (ZTA) across both public and private infrastructure.
• Enforce role-based access controls, multi-factor authentication, and session monitoring, especially for high-privilege users.
• Audit IT infrastructure for vulnerabilities and unauthorized access pathways on a regular basis.

5. Privacy Awareness and Organizational Culture

Key Insight: Lack of employee awareness and cybersecurity hygiene continues to be a leading vulnerability.

India's Imperative:

• Integrate data privacy training programs across organizations, with a special focus on employees handling personal data.
• Launch public campaigns promoting privacy rights awareness and safe data practices for citizens.
• Encourage the inclusion of privacy as a cultural pillar rather than a mere compliance requirement.

Conclusion

The global data breach underscores the fragile state of global data ecosystems, particularly in sectors that process vast volumes of personal and sensitive information. As India advances towards full enforcement of the Digital Personal Data Protection Act, 2023, it is imperative to internalize these global incidents as learning milestones.

By strengthening legal, operational, and cultural safeguards, India has the opportunity not only to secure its digital economy but also to emerge as a model jurisdiction for data protection in the Global South.