DPDP Act FAQs (2025 Edition): Consent, Revocation, Rights, Notices, Penalties & Compliance Explained

We have started the Digital Personal Data Protection (DPDP) Era, evolving at an incredible pace. With the stringent DPDP mandates, understanding how to manage user consent has become a game-changer for every enterprise in India. In this FAQ guide, we will try to answer almost all the pressing questions, starting from what consent managers are, how they work, what they are essential for DPDP compliance, and every other pressing question that would help the enterprises make more informed decisions. It doesn’t matter whether you are a compliance officer or a tech leader; this guide will equip you with the required information and knowledge to harness the complete power of consent managers and protect the enterprise from hefty DPDP penalties.

Q1. What is a Consent Manager?

Under the DPDP Act, a consent manager is an entity registered with the Data Protection Board acting as a single point of contact to help the user manager review, withdraw, and give their consent through a transparent, accessible, and interoperable platform.

In simple language, a consent manager ensures that the data principal has complete authority over their personal data and its processing.

For enterprises, a consent manager can be understood as a specialised software helping in compliance with data protection laws like the DPDP Act by handling user consent transparently and efficiently. A consent manager can be integrated into businesses to:

• Manage and collect consent across various channels.
• Provide individuals with the infrastructure to exercise their data access and rights to collection, correction, and deletion.
• Storing consent records in an interoperable and unified system.
• Ensuring the processing of third-party and internal data basis valid consent and deleting it whenever necessary.

Privy by IDfy, India’s first full-stack privacy governance and consent management platform provides a DPDP-aligned consent management ecosystem that goes beyond just collecting consent. Its Consent Governance Platform (CGP) manages consent lifecycles, multilingual notices, audit trails, and integrations across systems, making compliance simpler for large and complex enterprises.

Also Read : Top 5 Consent Management Platforms in India 2025

Q2. How does a consent manager work?

The functioning of a consent manager is based on the automation and centralisation of consent management across an organisation’s systems. This process involves:

1. Collection of Consent: Collecting user consent through apps, websites, email, and other various touchpoints with notices that are specific and clear.
2. Consent Check Integrations: Connecting marketing tools, CRM, and other systems to ensure that no data is processed without a valid consent.
3. Secured Storage: Storage of consent records with purpose, timestamps for an easy audit.
4. Compliance Support: Creation of detailed audit trails while ensuring data deletion and retention practices are in alignment with legal requirements.
5. User Rights Management: Letting users withdraw, modify, and review their consent via an accessible platform.

Also Read: The DPDP Compliance Checklist (2025): Step-by-Step Guide for Indian Businesses

Q3. How does an Ideal Consent Notice look?

An ideal consent notice has its requirements in a clear, concise, and compliant fashion. Under the DPDP Act, a consent notice should:

1. Use simple language: Jargon should be avoided, and the information presented in it should be easy to understand, along with its local language options available.
2. Be specific and informative: State the personal data being collected, the purpose for which it is being collected, and how it shall be used.
3. Explicit Action: It requires the users to provide explicit and affirmative consent, such as clicking a button or ticking boxes.
4. Highlight Rights: The individual must be informed about their rights to access data, revoke consent, and even file grievances.
5. Multilingual capability: The consent notice should be available in 22 languages as per the Eighth Schedule of the Indian Constitution.
6. Include a PoC: The user must be provided with the information on how to contact the organisation for any future assistan

Q4. How can one prove that the user consent was legally taken?

To ensure that the user consent is legally taken under the DPDP rules, the user must maintain verifiable records demonstrating compliance with legal requirements. This involves :

1. Consent Artifacts: Storing of digitally signed consent artifacts giving details about the data collected, the purpose for which it is being collected, and the explicit user agreement.
2. Records of Timestamp: Logs must be kept on when, where, and how the consent of the user was taken, including the exact date and time.
3. Clear Audit Trails: Maintain an audit trail showing the flow of the consent, including the consent notice being presented and an affirmative action from the user.
4. Consent Notice Details: ensuring the consent provided is compliant, including the specified details about data usage, local language options, and rights.
5. Withdrawal Audit Logs: Any instance of consent withdrawal must be tracked and documented, including the process of request acknowledgement and processing.

A content manager simplifies this entire process by organising and storing the records automatically in an accessible and secure format, ensuring audit readiness for the regulators.

Q5. Why should a Consent Manager be onboarded?

There are several advantages of onboarding a consent manager solution, including:

1. Enhanced Customer Trust: Providing transparency by letting users manage their consent preferences.
2. Ensured Compliance: Automating consent collection, audit trail, and management to meet the requirements of the DPDP Act.
3. Audit Preparedness: Maintaining a detailed record of all consent interactions for seamless audits and regulatory reviews.
4. Operational Efficiency: Streamlining consent-related workflows to ensure consistency across all platforms.
5. Interoperability: Storing of all consent in one place by using our interoperable and trusted consent records.

Privy by IDfy strengthens these benefits with features like Consent Shield (for tamper-proof storage), multilingual notice management, automated RoPA, and seamless integrations, giving enterprises a complete, DPDP-ready consent governance layer rather than just a basic consent collection tool.

Q6. Can personal data be processed without user consent?

Yes, but only under specific “legitimate uses” allowed by the DPDP Act, such as:

• When users voluntarily share data for a given purpose
• Employment-related processing like background checks
• Complying with court orders or laws
• Health emergencies where public safety is involved
• Disaster management and rescue operations
• Research and statistical work as long as individuals aren’t directly identifiable
• Legal investigations including preventing or detecting violations

Even in these scenarios, businesses must still follow key obligations like security controls, breach notifications, and grievance redressal.

Also Read : Complete Guide: India’s DPDPA Requirements for Cookie Consent

Q7. Are there any situations where the DPDP Act does not apply? Or what are the exemptions to this?

Yes, the DPDP Act provides certain exemptions where the obligations on compliance may be waived. These include:

• Corporate Mergers and Restructuring: data processing during acquisitions, mergers, or approved corporate restructuring.
• Financial Assessments: Financial institutions and banks can process personal data to assess the loan defaulters.
• Business Process Outsourcing (BPO): Indian enterprises processing foreign customer data under contract with a business that’s overseas
• Research and Statistics: Personal data might be used for analysis and research if individuals are not impacted.
• Legal and Judicial Proceedings: Processing personal data for disputes, regulatory investigations, and legal claims.
• Law enforcement and Investigations: data can be processed via prosecuting legal violations, preventing, and detectin

Additionally, when data for public services, law enforcement, and national security are being processed, government bodies are exempted. Children’s data can also be processed by hospitals, schools, and public welfare programs under certain conditions. While these exemptions do remove the consent obligations, businesses must still follow breach notification requirements and data security.

Also Read : Top 9 Features in a Data Privacy Management Platform

Q8. How can I take consent from children and people with disabilities?

When you’re collecting personal data from children or persons with disabilities, the DPDP Act expects you to take a few extra steps:

• Verify the user’s age : First, confirm whether the person is under 18 or has a disability. Use reliable checks like DigiLocker or AI-based age estimation.
• Verify the guardian : Make sure the parent or lawful guardian is an adult and has the authority to give consent on behalf of the child or the individual.
• Collect verifiable consent : Take clear, explicit consent from the guardian through secure methods such as DigiLocker Age Token, Aadhaar verification, or any strong identity-proof method.
• Avoid risky or harmful processing : Anything that could harm the child or vulnerable person, like targeted ads or behavioral tracking, must be strictly avoided.

Following these steps not only keeps you compliant but also protects the people who need that extra layer of care. Privy by IDfy supports verifiable, tamper-proof consent storage through its Consent Shield, ensuring that parental or guardian consent is securely logged, immutable, and audit-ready, especially useful for sensitive user groups.

Q9. What is the penalty for processing personal data without consent?

Processing someone’s personal data without proper consent can cost businesses up to ₹250 crore per violation under the DPDP Act.You may attract this penalty if you:

• Don’t take free, specific, explicit consent
• Show unclear or incomplete consent notices
• Share user data with third parties without consent
• Fail to keep verifiable consent records
• Keep user data even after consent has been withdrawn

The Data Protection Board decides the final penalty after looking at things like the severity of the violation, how long it continued, whether it happened repeatedly, and what mitigation steps your business took. Privy’s Consent Governance Platform automatically maintains versioned consent artefacts and audit trails, making it easier for businesses to demonstrate compliance and reduce the risk of penalty exposure.

Also Read : Penalties Under DPDP: Fines, Breach Scenarios, and How to Reduce

Q10. How do I take consent for data collected before the DPDP Act came into effect?

If you collected personal data before the DPDP Act was enforced, you need to send a one-time notice to those users. This notice should:

• Tell them what data you already have and why you collected it
• Explain how they can withdraw consent, request deletion, or exercise any other data rights
• Share grievance redressal details, your own and the Data Protection Board’s

If a user withdraws consent after receiving this notice, you must stop processing their data and delete it. This ensures that even older data meets current compliance standards.

Privy CGP offers a built-in Retrospective Consent Collection module, allowing you to automatically trigger bulk one-time notices and maintain compliant records for legacy data.

Q12. Can the one-time notice be sent in bulk to multiple users?

Yes. You can send the one-time notice in bulk by uploading an Excel sheet with user details. The system will automatically trigger the notice for each person no manual effort needed.

Privy’s bulk-notice workflows support large-scale consent refresh operations, ideal for enterprises digitizing older user bases.

Q13. How can I keep track of collected and pending consents?

You can monitor all consents using the Consent Register API, which logs every user response as it happens. Many businesses also maintain a consent dashboard for easy tracking. Webhooks for real-time consent status updates are on the way, too.

Q14. Do I need to take consent from offline users?

Yes. If you collect personal data offline and later digitize it, you still need to obtain consent that meets DPDP requirements. The format (offline or online) doesn’t change your obligation.

Q15. How can I collect valid consent for personal data gathered offline?

When data is collected physically, you can still capture valid consent through:

• Signed paper consent forms with a digital acknowledgment
• OTP-based verification
• Biometric authentication
• Or by sending a digital consent link via SMS or WhatsApp once the data is entered into your system

Any method is fine, as long as the consent is explicit, verifiable, and compliant.

Q16. Do I need consent for cookies on my website?

The DPDP Act isn’t very clear about cookies yet. But since cookies can qualify as personal data (because they track and identify users), it’s safer to follow best practices:

• Show a clear cookie notice explaining what you’re collecting and why
• Take explicit consent with a clear “Accept Cookies” action
• Give users an easy opt-out anytime
• Use a Consent Manager to keep the process compliant and logged