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Legal door · DPDP + BCI R.36 + POSH + LLP + CERT-In

Advocate-DPO ready. POSH-safe. BCI-aligned.

Your firm is a Data Fiduciary from the first payroll entry. HR, CRM, mailing lists, vendors, prospective-client intake — all in. Case files are the narrow carve-out. dcomply runs firm-side compliance (DPDP + POSH + BCI + LLP + CERT-In) and unlocks the Partner tier so you deliver advocate-DPO retainers to clients from one console.

one console · one login · six client DPO practices
PARTNER CONSOLE · 6 CLIENT TENANTS
REV. 2026.10

Six frameworks, one firm.

DPDP + BCI + POSH + LLP + CERT-In for your firm. Partner tier adds advocate-DPO delivery for your clients.

DPDP Act 2023 + Rules 2025 Firm as Data Fiduciary (HR, CRM, mailing, vendors). Case papers = narrow carve-out.
BCI Rules of Professional Conduct Rule 36 advertising + solicitation prohibition. Marketing pipeline review.
POSH Act 2013 IC with woman Presiding Officer + external member. Annual return by 31 Jan.
LLP Act 2008 Form 11 by 30 May + Form 8 by 30 October. Statutory audit thresholds.
CERT-In Directions 2022 6-hour report + 180-day log retention + named CISO for DMS / VDR / email.
Rule 36 BCI (marketing) Website allowed, solicitation not. Review flag on every outbound.

Four fires that cost the practice.

01

Privilege × client DSR. Client asks for their data. You redact work product + privileged material first. Need a workflow that flags matter-linked records before response goes out.

02

BCI Rule 36 on marketing. Website + articles + practice areas = allowed. Cold outreach + testimonials + comparative claims = not. Pipeline review flag catches it before send.

03

Matter retention vs DPDP erasure. Hold for ~7 years for professional-defence, then DPDP purpose-limitation kicks in. Two-phase policy, not a conflict.

04

Advocate-DPO as a recurring line. Firms running 6-10 client DPO practices on shared drives burn associates out. One console unlocks the Partner tier revenue.

Every firm module, plus the Partner tier.

Firm engagement from Rs 1,49,999 (45 days, sole-practitioner / small firm) or Partner tier (Rs 2,99,999 + per-client fees). Managed retainer from Rs 14,999/mo.

Law-firm compliance in four numbers.

Rs 250 Cr
Max DPDP penalty on firm-held data
31 Jan
POSH annual return deadline
30 May
LLP Form 11 deadline
7 yrs
Typical matter archival (professional-defence)

Questions managing partners actually ask.

Q 01
Does the DPDP Act apply to my law firm?

Yes, and it applies from the first payroll entry. The moment you hold personal data of employees, associates, prospective clients, vendors or newsletter subscribers, you are a Data Fiduciary. Even sole practitioners are covered. Case files are the only real carve-out, and even that is narrower than most partners think.

Q 02
I thought Section 17(1)(c) exempted us because we work with courts?

It only exempts what you process to enforce a legal right or claim, and what is processed by courts themselves for judicial functions. Case papers, pleadings, evidence, witness statements are fine. Your HR spreadsheet, associate onboarding folder, prospective-client intake form, the CRM you built in a weekend, the mailing list you export into Mailchimp, and last quarter's vendor invoices are all outside the carve-out. That is where DPDP hits your firm.

Q 03
How does privilege interact with a client asking for their data?

The client can ask. You can still redact work product and privileged material before you release. Section 12(4) lets you withhold where disclosure would harm a third party, and privilege under BSA 129/132 sits above discovery in any event. What matters is that you have a workflow to spot the matter-linked records before you send anything. Our DSR portal flags those records automatically so a partner reviews them before the response goes out.

Q 04
Can our firm be the DPO for our clients?

Yes, and a lot of Indian firms are already turning this into a recurring line. Section 10(2)(a) wants an India-based DPO reporting to the client's board. An advocate on retainer ticks both boxes. The hard part is delivery — running six or ten client DPO practices out of shared drives and emails burns your associates out fast. The Partner tier gives you one console and one login for all of them.

Q 05
What about BCI Rule 36 on advertising?

Rule 36 was liberalised in 2008. You can run a website. You can publish articles. You can list your practice areas and contact details. What you cannot do is solicit — no cold outreach, no comparative marketing, no client testimonials that read like endorsements. Anything the firm sends outbound goes through our BCI review flag before it leaves the outbox.

Q 06
Is POSH really mandatory for a law firm?

Yes. The POSH Act applies to any workplace with 10 or more employees, and that includes partnerships, LLPs and chambers. You need a constituted Internal Committee with a woman Presiding Officer and an external member, an annual return to the District Officer by 31 January, and quarterly awareness sessions on the record.

Q 07
Does CERT-In apply to us?

The April 2022 Direction applies to any entity running ICT infrastructure that suffers a reportable incident. Ransomware on your DMS, an unauthorised access to your VDR, or a compromised mail server — all in scope. Six-hour report window, 180-day log retention, named CISO. Legal DMS platforms are already inside CERT-In's attention radius after the 2023 wave of law-firm ransomware.

Q 08
How exposed are we on penalties?

The biggest number is Rs 250 crore for a security-safeguards failure under Section 8(5). Add up to Rs 200 crore for missing the breach notification under Section 8(6). And the fine on your firm does not extinguish the parallel BCI professional-misconduct route, nor does it protect the client whose data leaked.

Q 09
We are an LLP. What extra filing burden does that add?

Two annual filings under the LLP Act 2008. Form 11 by 30 May, Form 8 by 30 October. Statutory audit if turnover crosses Rs 40 lakh or partner contribution crosses Rs 25 lakh. If you receive supplies from MSME vendors, add the MSME-1 half-yearly.

Q 10
Can we white-label this for our clients?

Yes. The Partner tier gives you co-branded tenants at yourfirm.dcomply.in with your masthead, per-client evidence isolation, and consolidated billing. The client sees your firm brand. Their engagement letter with you is still the DPA. We are the platform underneath.

Q 11
Doesn't a DPDP breach notice violate advocate-client confidentiality?

It does not. Privilege is a rule of evidence — it stops compelled testimony in court. It is not a gag on statutory disclosure obligations. The Rules 2025 template limits what goes to the DPB to breach facts and mitigation steps, not the content of any privileged matter.

Q 12
What about matters we close but archive for professional-liability defence?

Advocates practice tends to hold matter files for around seven years for professional-defence reasons. That is fine — retain them, but tag them as archival-retention. When the archival period expires, DPDP purpose-limitation kicks back in and the Retention module flags the file for review or deletion. It is a two-phase policy, not a fight between the two frameworks.

Request a scope. Run the Partner tier under your brand.

Firm engagement from Rs 1,49,999 (45 days). Partner tier from Rs 2,99,999 + per-client fees. Managed retainer from Rs 14,999/mo.