1) Consent Issues
Disputes arise when personal data is processed without valid, free, informed, and specific consent.
- Invalid or missing consent
- Forced or bundled consent (no real choice)
- Consent withdrawal ignored
- Misleading consent mechanisms (dark patterns / coercion)
- Using data for a new purpose without fresh consent
2) Notice Failures
Disputes occur when individuals are not clearly informed about data collection, use, and grievance options.
- No notice provided
- Vague or incomplete notice
- Notice not understandable (language / accessibility)
- Notice not updated when purpose changes
3) Rights Denied
Individuals have rights such as access, correction, and erasure. Disputes happen when these are denied or delayed.
- Access requests denied
- Correction requests denied
- Erasure requests denied
- Grievances ignored or no mechanism provided
- Nominee rights not recognized
4) Security Lapses
Organizations must implement reasonable safeguards to protect personal data.
- Weak security controls / inadequate safeguards
- Poor internal access controls
- Failure to appoint grievance officer / public contact point (where required)
- Collecting more data than needed or retaining data too long (often linked to security risk)
5) Data Breaches
When breaches occur, timely notification and mitigation are key. Disputes arise from delays or negligence.
- Breach not notified to affected individuals / authority
- Unreasonable delay in notification
- No meaningful mitigation/remedial action
- Breach due to preventable negligence
6) Children’s Data
Children’s personal data requires higher protection, including verifiable parental consent.
- No verifiable parental consent
- Tracking/profiling of children
- No effective age verification controls
7) Cross-Border Transfers
International transfers may be restricted or require safeguards and transparency.
- Transfer to restricted/non-approved countries
- No safeguards for international transfer
- Transfer not disclosed to individuals (where required)
8) SDF Non-Compliance
Significant Data Fiduciaries (SDFs) have additional obligations for high-risk processing.
- DPO not appointed (where required)
- DPIA not conducted (where required)
- Lack of accountability for automated/algorithmic decisions
9) Enforcement & Complaint Issues
Disputes can arise during grievance handling and enforcement processes.
- Complaint rejected without proper inquiry
- Non-compliance with binding orders
- Frivolous/vexatious complaints
- Jurisdiction disputes on whether DPDPA applies
Disclaimer: For user awareness only. Not legal advice. Consult a qualified data protection lawyer for specific matters.