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Product · 8 min read · Jun 2026

DPDP Consent and Consent Managers: Turning Legal Requirements Into Everyday Product Design

DPDP Consent and Consent Managers: Turning Legal Requirements Into Everyday Product Design

W2 BI1.png# DPDP Consent and Consent Managers: Turning Legal Requirements Into Everyday Product Design

Published by Vishwaas.ai | DPDP Series

In India's DPDP world, "consent" is much more than a checkbox on a signup form. It is the default legal gateway for processing most personal data and, in practice, the first real touchpoint where your users decide whether they trust your product.

Under Section 6 of the Digital Personal Data Protection Act, 2023, consent must be free, specific, informed, unconditional and unambiguous, and it must be given through a clear affirmative action. The DPDP Rules 2025 go further and explain how notices and consent experiences should actually look and how a new player - the Consent Manager - will help individuals manage consents across multiple services.

For SaaS teams and digital businesses, that means consent is not just a legal phrase tucked into a privacy policy, but a core part of product, UX and data-governance design.

DPDP's definition of consent borrows the clarity of global regimes like GDPR but is adapted to the Indian context. In simple terms, for consent to be valid:

  • Free – Users are not coerced into agreeing, and they are not forced to waive statutory rights as a condition for using the service.

  • Specific – Consent is tied to a clearly stated purpose, not a vague, bundled "we will use your data for everything" clause.

  • Informed – Users receive a clear notice explaining what data will be processed, for what purposes, how they can exercise their rights, and how to complain.

  • Unconditional and unambiguous – No pre-ticked boxes, no silence treated as consent, no confusing opt-out flows; the user must actively say "yes" for the specified purpose.

  • Affirmative action – The law expects a positive action such as clicking "Accept", toggling a control, or performing a clearly consent-linked step.

If any part of the consent breaks these rules - say, if you bundle unrelated processing purposes together or hide key information in dense legal language - that part of the consent is invalid under DPDP.

3. Notice + Consent: Two Sides Of The Same User Moment

DPDP treats notice and consent as a single, connected experience. The Act and Rules require Data Fiduciaries to give plain-language notices before seeking consent, covering at least:

  • What categories of personal data will be processed.

  • For what specific purposes.

  • How long the data is likely to be retained, or the criteria for deciding that.

  • How the Data Principal can exercise rights like access, correction, erasure and grievance.

  • Contact information of a person or office who can answer questions about processing.

Notices and consent requests must be available in English or any Eighth Schedule language so that individuals are not locked out because of language barriers.

From a product perspective, this pushes teams to treat consent screens and privacy banners as core UX journeys: they should be readable, purpose-specific, and easy to revisit.

One of the most human-centred aspects of DPDP is its insistence that withdrawing consent should be as easy as giving it. If a user changes their mind, the Data Fiduciary must:

  • Stop processing their personal data for that purpose, unless a different legal basis exists to continue.

  • Ensure Data Processors acting on their behalf also stop further processing for that purpose.

  • Delete or anonymise the data where appropriate, subject to legal retention obligations.

This means UX patterns like "email us to unsubscribe" or "call customer care" are no longer acceptable for core consent withdrawal. Users must be able to withdraw through the same or similar digital interface where they gave consent in the first place.

The DPDP Act introduces the concept of a Consent Manager - a specialised Data Fiduciary registered with the Data Protection Board that acts as a neutral platform for giving, managing and withdrawing consent across multiple services.

According to the DPDP Rules 2025 and official insight briefs:

  • A Consent Manager must be an Indian-incorporated company meeting conditions set out in Part A of the First Schedule (including net-worth, governance and technical capability).

  • It must register with the Data Protection Board and is listed publicly once approved.

  • It must develop and maintain a website or app - or both - as the primary interface for Data Principals.

  • It acts as a single point through which individuals can grant, manage or withdraw consents given to multiple Data Fiduciaries.

Think of a Consent Manager as a "consent wallet" where a user can see, at a glance, which apps and services they have allowed to process which parts of their data - and can revoke or change those permissions without navigating ten different settings menus.

Registration is only the starting line. Once registered, Consent Managers must follow obligations in Part B of the First Schedule of the Rules. Common themes across legal and practitioner commentary include:

  • Providing user-friendly tools for granular consent management.

  • Maintaining accurate, tamper-resistant logs of consent actions.

  • Implementing strong security safeguards and privacy-by-design in their platforms.

  • Acting in the interest of Data Principals and remaining neutral - not skewed toward any single service provider.

Non-compliance carries real enforcement risk: DPDP allows the Board to suspend or cancel a Consent Manager's registration after giving a fair hearing, and monetary penalties for Consent Manager failures can go up to ₹50 crore in certain scenarios.

So while Consent Managers are powerful enablers of user autonomy, they are also heavily accountable, and must treat privacy and uptime as mission-critical.

Analyses of the Rules indicate a balanced approach:

  • Data Principals are not forced to use Consent Managers; they can continue to manage consent directly with each service.

  • Consent Managers must be registered within a year of Rules notification, creating an ecosystem of trustworthy platforms.

  • Regardless of whether a Consent Manager is used, Data Fiduciaries remain responsible for proving that consent was validly obtained, recorded and respected.

For product teams, this means preparing for two modes:

  • Direct consent flows within your app or SaaS product.

  • Integration points where a Consent Manager forwards consent instructions, revocations or corrections that your backend has to honour.

8. What This Means For Your Product And UX

Translating DPDP's consent requirements into day-to-day product work typically involves a few practical shifts:

  • Purpose-specific forms and toggles – Break down consent into clear, distinct purposes (e.g., "service delivery", "analytics", "marketing") instead of a single bundled approval.

  • Readable privacy notices – Design short, layered notices that summarise the essentials up front and link to more detailed explanations.

  • Easy revocation – Include clear paths in settings, dashboards or profile pages where users can change or withdraw consent in one or two steps.

  • Audit-ready logs – Maintain structured, time-stamped records of consent events that can be produced to the Board or auditors if needed.

  • Language flexibility – Offer consent flows in relevant languages for your user base, aligned with DPDP's language expectations.

On the engineering side, consent states should drive actual behaviour: if marketing consent is off, campaigns should skip those users; if analytics consent is withdrawn, event pipelines should stop tracking or promptly anonymise their data.

DPDP adds specific rules for consent when children or certain persons with disabilities are involved. The Rules require:

  • Verifiable parental or guardian consent before processing a child's personal data, except for some essential services such as healthcare or education.

  • Structured mechanisms for verifying that the person providing consent is an identifiable adult with lawful authority - not just someone ticking a box.

  • Special handling and potential exemptions for essential services and for persons with disabilities who have lawful guardians.

For products, this translates into age-gating, guardian verification flows, conservative defaults for tracking and advertising, and clear logs of how child or PWD consent was obtained.

When consent is treated only as a legal requirement, it often ends up as a dense wall of text that users click through. DPDP pushes organisations to re-imagine consent as a trust-building feature:

  • Clear, unbundled choices signal respect for user autonomy.

  • Easy withdrawal tells users they are not locked in.

  • Integration with Consent Managers shows you are willing to share control rather than hoard it.

For companies like Vishwaas.ai, which live at the intersection of privacy, compliance and product design, this creates a natural opportunity: build DPDP-aligned consent journeys that are both legally sound and user-friendly, and turn what was once a risk topic into a differentiator in your SaaS story.

© Vishwaas.ai | DPDP Compliance Made Simple

Last updated 29 Jun 2026, 12:45 IST · published 29 Jun 2026, 12:35 IST