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Q1 - Can the Board initiate an investigation on its own, or only based on complaints?

Answer
  • Yes, the Board can act suo motu (on its own initiative).
  • Apart from individual complaints, the Board may investigate if it learns of a breach or violation from media reports, whistleblowers, or breach notifications.
  • This makes enforcement proactive, not just reactive.
Example
  • If news breaks that XYZ E-commerce leaked millions of customer addresses online, the Board does not need to wait for complaints. It can start an inquiry directly.