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For product managers

Most DPDP duties show up as screens, flows and events. Product teams decide whether consent is real, whether withdrawal is easy, and what the analytics pipeline collects.

Updated 4 Nov 2026

Short answer

Consent under s.6 must be free, specific, informed, unconditional and unambiguous with a clear affirmative action, limited to data necessary for the purpose, and withdrawal must be as easy as giving it (s.6(4), Rule 3). Users under 18 need verifiable parental consent (s.9(1), Rule 10), with no tracking or targeted ads directed at them (s.9(3)). Analytics events tied to an identifiable user are personal data, so they need a purpose too.

Consent is a product surface. Each pattern below is a way to meet s.6 and Rule 3.

  • One purpose per choice. Bundled consent is not specific.
  • Store the notice version with each consent, so legal can prove it later (s.6(10)).
  • No pre-ticked boxes. They are hard to square with a clear affirmative action.
  • Reject as visible as accept, and no repeated prompts after a no.
  • The notice next to the choice, itemised, not only a link to a long policy (Rule 3).
  • Withdrawal in the same place, with the same number of steps, as giving consent (s.6(4)).
  • Do not make a service depend on consent to data it does not need (s.6).

Keep a purpose register

Every feature that touches personal data should map to a row. When a roadmap item adds a purpose, the register changes before the code ships. A sample for a fictional app, Example Lending:

PurposeDataGroundOwner
Loan applicationName, PAN, income documentsConsent (s.6)Lending product
Repayment remindersMobile number, due dateConsent (s.6)Servicing
Product analyticsUser ID, screen eventsConsent (s.6)Growth
Offers from partnersName, emailSeparate optional consent (s.6)Marketing

Children's flows

If under-18s can use the product, design for it. Ask age at sign-up, route minors to a parental consent step that checks the parent is an identifiable adult (Rule 10), and switch off tracking and targeted ads for them (s.9(3)).

For a child, the Data Principal includes the parent (s.2), so build parent access to requests and withdrawal. Rule 12 exemptions apply only to listed classes and purposes, within conditions; do not design around one without counsel.

Instrumentation is personal data

Event streams, session recordings and crash logs that carry a user ID, device ID or phone number relate to an identifiable person. Treat each event as data with a purpose, a retention period and a row in the register. Session replay needs extra care because it can capture whatever users type.

What to do this quarter

  1. 01Audit the event schema

    List analytics events tied to user IDs, and drop the ones no purpose needs.

  2. 02Inventory SDKs

    List third-party SDKs per build, and what each collects and sends.

  3. 03Fix withdrawal

    Put consent settings where users gave consent, and test that withdrawal reaches every downstream tool.

  4. 04Ask legal and security

    Get notice text from legal, and confirm with security which new stores will hold personal data.

How TruePrivacy helps

  • Consent management holds purposes, a record per person and purpose, a preference page and an event log, with SDKs for iOS, Android and React Native and a web banner script.
  • Cookie consent scans your site for trackers so they become consent purposes; banner text ships in English and all 22 Eighth Schedule languages.
  • Parental consent handles the guardian request by email, verification with a code, the recorded decision and revocation.
  • Records of processing hold your processing activities, synced from discovery and exportable, as the system version of your purpose register.

Sources

  • Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023)
  • Digital Personal Data Protection Rules, 2025, G.S.R. 846(E), 13 November 2025

Updated 4 Nov 2026. Educational information, not legal advice.

Questions, answered

Educational, not legal advice.

All DPDP FAQs
Can we pre-tick a consent box?

Consent needs a clear affirmative action (s.6). A pre-ticked box is hard to square with that.

How easy must withdrawal be?

Comparably as easy as giving consent (s.6(4), Rule 3). If consent took one tap in the app, withdrawal should not need an email to support.

Are product analytics personal data?

Yes, where events relate to an identifiable person, such as through a user ID or phone number (s.2).

Do teenage users need parental consent?

Yes. Anyone under 18 is a child under DPDP (s.2), so s.9 and Rule 10 apply unless a Rule 12 exemption fits within its conditions.

Your DPDP plan, starting today

Core obligations for data fiduciaries begin on 13 May 2027.

13 May 2027

Core obligations begin