Most organisations operating in India today already collect consent. It appears during onboarding flows, within privacy notices, and it is interwoven into standard digital interactions. From a distance, this gives the impression that consent is already “handled”. Under the Digital Personal Data Protection (DPDP) Act, that assumption no longer holds.

To understand why, let us break this down with the example of a common operational scenario!

A regulated financial services company (bank, NBFC, or fintech) has been collecting customer data for years. Consent is captured at onboarding and stored somewhere within the system. Data flows onward to internal analytics, service providers, verification partners, and downstream processors. At some point, a straightforward question is raised internally:

“If a customer withdraws consent today, can the organisation confirm with certainty that their personal data has stopped being processed across every system and partner?”

In many organisations, this is where clarity gives way to ambiguity! Some teams assume consent withdrawal is handled at the application layer. Others believe contractual obligations with processors are sufficient. Legal teams may be confident consent was validly obtained, while engineering teams focus on system-level controls in isolation. What DPDP exposes is not a lack of intent, but a lack of governance.

The core issue is this: consent has traditionally been treated as a point‑in‑time action! But the new DPDP requirement reframes consent as an ongoing obligation that must be governed, enforced, and demonstrated throughout its entire lifecycle. 

This is where the distinction becomes critical: Consent capture answers whether a user agreed at a moment in time while consent lifecycle management determines what happens to that agreement as systems evolve, purposes change, data moves, and users exercise their rights.

Consent governance ensures that this lifecycle is controlled, accountable, and auditable. Under DPDP, these elements cannot exist independently. A consent that is captured but not enforced, stored but not traceable, or revoked but not propagated is not defensible regardless of how clearly it was originally presented. The Act shifts the regulatory lens away from whether consent was taken to how consent was managed. Data fiduciaries are now expected to demonstrate that consent was purpose‑specific, actively enforced at the point of data use, capable of being withdrawn without friction, and reconstructible during regulatory scrutiny.

This expectation has direct operational consequences since organisations can no longer rely on fragmented implementations where consent lives in silos. What is required instead is a governed consent lifecycle, supported by defined ownership, clear control points, and systems designed to enforce consent as data moves.

The Consent Lifecycle under DPDP: 

1. Consent Notice Design: Establishing Purpose Before Data Collection
   At the start of the lifecycle, consent is shaped long before it is captured. This stage defines why personal data is collected and how that purpose is communicated. Purpose descriptions, data categories, and usage boundaries are articulated here, forming the legal and operational foundation for all downstream processing. Governance at this stage requires a centralised purpose registry and version‑controlled consent notices. Legal validation, product alignment, and compliance sign‑off must be completed before notices are deployed. Without formal governance here, organisations risk vague or over‑broad purposes that cannot be enforced later.
   
2. Consent Capture: Binding User Choice to a Verifiable Context
   Consent capture is the point at which a user actively agrees to a defined purpose. This typically occurs across digital channels such as web, mobile, or assisted journeys. The act of consent must be explicit, informed, and tied to a specific notice presented at that moment.Effective governance ensures that every consent record is linked to a notice version, capture timestamp, language, and channel. Capture mechanisms must prevent pre‑selection or implied consent. From a fiduciary perspective, the key question is not whether consent was obtained, but whether the exact context of that consent can be reliably reconstructed.
   
3. Consent Storage and Recordkeeping: Creating a System of Evidence
   Once captured, consent transitions from a user interaction to a compliance artefact. It must be stored as an immutable record that can withstand audit scrutiny and internal verification. At scale, this becomes a data management problem rather than a UI concern. Governance controls require a standardised consent data model, secure storage, and defined retention rules aligned to purpose validity. Records must be tamper‑resistant and machine‑verifiable. For FIs, this stage should answer a critical question. i.e can consent be proven independently of the application that collected it?
   
4. Purpose Enforcement: Governing Data Use at Runtime
   Purpose enforcement is where consent becomes operationally meaningful. Every instance of data access or processing should be evaluated against the consent granted by the user. This occurs deep within systems, APIs, and data pipelines. Governance here demands real‑time consent validation, purpose‑based access controls, and deny‑by‑default logic when consent is absent or invalid. Enforcement must be systemic! Without runtime governance, consent remains declarative rather than enforceable and exposes FIs to silent non‑compliance under the new DPDP requirements even when consent records exist.
   
5. Consent Change and Re‑Consent: Managing Purpose Evolution
   Over time, products evolve, features expand, and data uses shift. When the original purpose no longer fully reflects current processing, consent must be reassessed. This stage governs how organisations respond to change without compromising user rights. Effective governance requires clear criteria for identifying purpose drift, automated detection of consent‑version mismatches, and controlled re‑consent workflows. Decisions around re‑consent must be documented and consistently applied. For fiduciaries, this stage mitigates the risk of continuing data use based on outdated or incomplete consent.
   
6. Consent Withdrawal and Revocation: Enforcing User Control 
   Revocation marks the user’s right to withdraw consent and must be treated as a high‑priority operational event. Data processing associated with the revoked purpose must cease, and the change must propagate across all systems and processors. Governance controls include a single revocation interface, defined service‑level timelines, and confirmation mechanisms from downstream processors. Exceptions, such as legally mandated retention, must be explicitly governed. From a fiduciary standpoint, revocation is only complete when it is enforced end‑to‑end, not when the request is merely received.
   
7. Audit and Oversight: Demonstrating Lifecycle Accountability
   The final stage consolidates all prior activity into an auditable narrative. Regulators and internal auditors will assess not isolated actions, but the coherence of the entire consent lifecycle for individual data principals. Governance at this level requires consolidated reporting, traceability across stages, and the ability to reconstruct consent journeys quickly. Exception handling, delays, and deviations must be visible and explainable. This stage ultimately determines whether consent governance exists only in theory or operates as a defensible system in practice.

Governance Layer: Making Consent a Managed System

Consent governance is what transforms consent from a compliance requirement into a managed operational capability. While the consent lifecycle defines how consent moves through an organisation, governance determines whether that movement is controlled, consistent, and defensible. Under DPDP, this distinction is critical.

Governance introduces discipline across legal interpretation, product execution, and technical enforcement, ensuring that consent remains aligned with stated purposes even as data flows grow more complex. At its core, consent ensures that consent decisions are repeatable, auditable, and accountable regardless of scale. Without this layer, even well‑designed consent journeys risk breaking down under operational pressure, system changes, or regulatory scrutiny.

Core Governance Pillars 

Consent governance rests on four interdependent pillars. Policy defines clear consent standards and a structured purpose taxonomy that guides all data use. Process ensures that changes to consent, purposes, or notices move through formal approval, review, and escalation workflows. Technology operationalises governance through consent managers, runtime enforcement mechanisms, and audit capabilities. Oversight closes the loop through metrics, periodic reviews, and clearly assigned accountability. Together, these pillars ensure that consent is not only captured correctly, but governed consistently across its entire lifecycle.

Consent Governance Checklist (A Quick Reference for Data Fiduciaries)

Purpose registry maintained: All data uses map to approved, documented purposes.

Notice versions tracked: Every consent is tied to a specific, immutable notice version.

Consent schema standardised: Consent records follow a uniform, auditable data model.

Runtime enforcement enabled: Data access is validated against consent at the point of use.

Re‑consent triggers defined: Purpose changes automatically initiate consent review.

Revocation SLAs enforced: Withdrawal of consent propagates within defined timelines.

Audit reports automated: End‑to‑end consent evidence can be generated on demand.

Conclusion 

The Digital Personal Data Protection (DPDP) Act is no longer a distant regulatory milestone. With its phased enforcement imminent, the window for conceptual preparation has closed. What now matters is execution and the ability to demonstrate that execution with evidence. Consent governance under DPDP is not something that can be retrofitted at the last moment. It requires changes to data models, workflows, ownership structures, and enforcement mechanisms that take time to design and stabilise. Organisations that delay operationalising consent risk entering enforcement cycles with fragmented controls, manual workarounds, and limited audit confidence.

This is why the shift from governance to execution is urgent. Purpose definitions must already be embedded into data flows. Consent validation must occur at runtime, not during audits. Revocation must be enforceable across systems and partners as a matter of routine, not exception. When DPDP comes into effect, regulators will assess readiness based on how consent operates in practice and not on policy intent.

If your organisation is at the stage of translating DPDP requirements into executable consent management systems, Perfios can help. Our experience in building and operating regulated data ecosystems enables consent governance to be embedded directly into data workflows with the rigour and scale DPDP demands.

To discuss how Perfios can support your DPDP consent management readiness, reach out to our team!