How Consent Management Platforms Should Align with Business Requirement Document (BRD) Released by MeitY and the DPDPA, 2023

As organizations transition toward a privacy-first ecosystem under India’s Digital Personal Data Protection  Act, 2023, the need for a robust, transparent and user-centric Consent Management Platform has become fundamentally important. For companies, startups, and enterprise-scale data fiduciaries, compliance is no longer a checkbox exercise; it requires building systems that inherently support individual rights, granular data autonomy, and real-time consent governance.

At ComplyPlanet, we recognize that the cornerstone of regulatory compliance lies not just in lawfully collecting consent, but also in managing it throughout its lifecycle collection, validation, update, renewal, withdrawal, logging, grievance management and more. A well-architected CMP ensures transparency, trust and operational efficiency for all stakeholders.

Purpose and Significance of a Consent Management Platform

A CMP is designed to give Data Principals full authority over their personal data and their consent choices. It must support the complete lifecycle of consent, which includes collection, validation, renewal, modification, and withdrawal. The platform should offer an intuitive user experience where individuals can view their active and past consents, modify preferences, or revoke consent without friction. 

At the same time, it assists Data Fiduciaries and Processors by generating secure consent artifacts, maintaining audit logs, issuing compliance alerts, and ensuring processing activities remain purpose-bound. By aligning with the DPDP Act’s core principles such as lawful processing, purpose limitation, data minimization, user rights, and accountability the CMP becomes central to building a compliant digital ecosystem.

Stakeholders in the Consent Ecosystem

Data Principal

  • Ability to provide free, informed, specific, and unambiguous consent.
  • Simple and intuitive mechanisms to grant, review, modify, renew, or withdraw consent at any time.
  • Transparent visibility into what data is collected, for what purpose, and by whom it is processed.
  • Access to consent history and records for accountability and trust.

Data Fiduciary

  • Capability to create and issue consent requests aligned with defined purposes and lawful use.
  • Real-time validation and tracking of consent status across systems and processing activities.
  • Automated management of consent lifecycle, including expiry, renewal, and withdrawal.
  • Audit-ready documentation to demonstrate compliance with DPDP Act requirements.

Data Processor

  • Immediate and automated receipt of consent status updates from the CMP.
  • Clear, purpose-bound authorization to process personal data strictly as permitted.
  • Technical controls to halt processing upon consent withdrawal or modification.
  • Verifiable logs evidencing compliant data processing activities.

Data Protection Officer (DPO)

  • Centralized dashboards providing a holistic view of consent governance.
  • Access to detailed reports, logs, and compliance metrics for monitoring and audits.
  • Tools to identify gaps, risks, and non-compliance in consent management practices.
  • Oversight mechanisms to ensure continuous adherence to regulatory and internal policies.

Designing the Consent Lifecycle as per the BRD

The BRD outlines a structured consent lifecycle that every CMP must incorporate. The process begins with transparent and granular consent collection. The interface must be both user-friendly and compliant with Web Content Accessibility Guidelines (WCAG), ensuring accessibility for individuals with disabilities. 

Consent prompts must clearly articulate the purpose and scope of data processing, allowing users to make informed decisions. The system must avoid bundled consent practices; instead, each purpose such as service delivery, analytics, marketing, or personalization must have individually selectable options. Users must provide explicit, affirmative actions, as pre-checked boxes or silent acceptance mechanisms are not permitted under the DPDP framework. Multi-language support is essential, with consent notices available in English and multiple languages from the Eighth Schedule of the Constitution, enhancing inclusivity.

Every consent submission must generate robust metadata, including user ID, purpose ID, timestamp, language preference, and consent status. After validation, the CMP must create a detailed consent artifact documenting user actions and decisions. This artifact should synchronize immediately across all downstream systems, Data Fiduciaries, and Data Processors through secure API integrations. Such real-time synchronization ensures that organizations always operate based on the user’s latest consent preferences.

Validating Consent Before Data Processing

Before a Data Fiduciary or Processor initiates any processing activity, the CMP must validate whether active consent exists for the specific purpose. Validation includes checking whether consent is valid, ensuring timestamps and purpose IDs align correctly, and confirming that processing does not extend beyond the stated purpose. This step safeguards users and prevents unlawful handling of personal data. Every validation request regardless of outcome must be logged to support compliance audits and disputes. By enforcing strict pre-processing validation, the CMP helps organizations maintain integrity across their data workflows.

Managing Consent Updates and Changing Preferences

As organizations evolve their services, new processing purposes may emerge, or users may wish to modify their existing choices. The CMP must allow Data Principals to update consent just as easily as they initially provided it. Whenever new processing purposes are added, users should be notified promptly. The system should allow them to accept or decline each new purpose independently. Every update must record user ID, purpose ID, and timestamp, ensuring each adjustment is preserved for audit purposes. The CMP must propagate these updates across all systems in real time, enabling Data Fiduciaries and Processors to instantly adapt their workflows according to user preferences.

Renewing Consent for Time-Bound Processing

In cases where consent has an expiration period such as recurring authorizations or regulatory requirements the CMP must track these deadlines and send timely reminders to users. Renewal should be simple and intuitive, enabling users to reconfirm their consent without navigating complex interfaces. Upon renewal, the CMP must generate an updated consent artifact and notify all relevant stakeholders. Renewal events must also be logged comprehensively to support transparency and auditability. This mechanism ensures that Data Fiduciaries never rely on outdated or expired consent during data processing.

Renewing Consent for Time-Bound Processing

n cases where consent has an expiration period such as recurring authorizations or regulatory requirements the CMP must track these deadlines and send timely reminders to users. Renewal should be simple and intuitive, enabling users to reconfirm their consent without navigating complex interfaces. Upon renewal, the CMP must generate an updated consent artifact and notify all relevant stakeholders. Renewal events must also be logged comprehensively to support transparency and auditability. This mechanism ensures that Data Fiduciaries never rely on outdated or expired consent during data processing.

Allowing Seamless and Immediate Consent Withdrawal

According to the DPDP Act, withdrawing consent must be as effortless as granting it. A compliant CMP must offer a clear and intuitive withdrawal option within the user dashboard. Before withdrawal, users should be informed of the implications, such as possible service limitations. Once consent is withdrawn, the CMP must instantly halt all processing activities associated with the revoked purpose. 

Notifications must be sent in real time to both Data Fiduciaries and Processors. The system must update the consent artifact to reflect the withdrawal and log the event with full metadata, including user ID, purpose ID, timestamp, and status. Even in cases where certain processing may continue for legal or regulatory reasons, the CMP must handle such exceptions with precision and transparency.

Cookie Consent Management for Digital Tracking

Given the importance of online privacy, a CMP must include a dedicated cookie consent module that aligns with digital tracking requirements. This module should categorize cookies based on purpose such as essential, analytics, and marketing and allow users to customize preferences easily. 

Cookie banners must appear upon the first website visit, offering options to accept, reject, or configure settings. The system must support multi-language notices, detailed cookie explanations, and auto-expiry of preferences. All cookie selections must be logged with timestamps and metadata, enabling organizations to demonstrate compliance with privacy regulations.

A User-Centric Dashboard for Transparency

The user dashboard is a critical component of the CMP and must offer complete visibility into consent history. Users should be able to view active, expired, and withdrawn consents, including timestamps, purpose IDs, and consent details. Downloadable reports in formats such as PDF or CSV may enhance transparency. Users must be empowered to modify or revoke consent instantly, with real-time updates across systems. Additionally, the dashboard must provide an integrated interface for grievance submissions and data access, correction, or erasure requests. Each grievance must generate a unique reference number, be securely recorded, and include automated updates and escalation to the DPO when necessary.

Notifications for Transparency and Compliance

The CMP must incorporate robust notification systems for all stakeholders. Users must receive alerts for approvals, withdrawals, renewals, and data request updates via email, SMS, or application notifications. Data Fiduciaries and Processors must receive alerts for new consents, withdrawal notices, status changes, expiration warnings, and compliance-related checks. Every notification must be logged to ensure transparency and support regulatory reporting.

Secure Administration and Governance Controls

On the administrative side, a CMP must include strong governance controls through Role-Based Access Control (RBAC). Administrators, Operators, Auditors, DPOs, and custom roles must be configured with appropriate access privileges. Multi-factor authentication and access logs ensure security and traceability. Additionally, the CMP must support data retention configurations, allowing administrators to define retention periods for consent artifacts, schedule automatic deletions, and handle legal exemptions. Pre-deletion alerts and comprehensive logs ensure that all retention actions comply with regulatory requirements.

The Role of Logging and Audit Trails

The BRD emphasizes that immutable audit logs are foundational to compliance. The CMP must record every consent-related action, including grants, updates, withdrawals, validations, notifications, and metadata like user ID, purpose ID, timestamps, IP address, and cryptographic hashes. These tamper-proof logs support audits, regulatory submissions, and dispute resolution, forming the backbone of accountability within the consent ecosystem.

Conclusion:

Constructing a fully compliant Consent Management Platform under the DPDP Act requires deep attention to detail, user experience and stringent adherence to functional requirements. The BRD provides a comprehensive framework, one that enables organizations to implement a system built on transparency, user rights, real-time synchronization and audit readiness.

ComplyPlanet helps organizations to implement a fully compliant consent management platform aligned with the DPDP Act. Our platform simplifies consent lifecycle workflows, automates validation and ensures multilingual, transparent user experiences. With end-to-end compliance support, we enable businesses to become truly DPDPA-ready with speed, accuracy and trust.

Start early and let ComplyPlanet help you build a compliant, secure, and privacy-driven future.

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