DPDP Rulebook for Product Managers: From User Onboarding to Consent Flows

With the Digital Personal Data ProtectionAct (DPDP Act) in force and the Rules, 2025 officially notified, Product Managers are now at the forefront of India’s privacy-first digital shift.
No longer just a legal or backend concern, DPDP compliance is now a product-level responsibility impacting every screen, form, click, and consent toggle.

This blog unpacks what every product team must do to stay compliant and design trust-driven digital journeys in 2026.

Why Product Managers Must Care About DPDP

Under the DPDP framework:

• Consent isn’t backend logic, it’s a UI/UX responsibility

• Onboarding isn’t just user capture it must be privacy-aware by design

• Default settings, cookie banners, and opt-ins are all regulatory touchpoints

Ignoring these means risking non-compliance, ₹250 crore fines, and user churn.

Your DPDP Compliance Checklist: Product Manager Edition

Here are the 7 areas where your product roadmap must evolve:

1. DPDP-Compliant Onboarding Screens

What’s required:

• Clear, layered notices before data collection

• “Purpose-first” onboarding tell users why each data point is needed

• Option to opt-out of non-essential flows (e.g., tracking, cross-platform sync)

Tip: Avoid forced bundling consent must be free, specific, and granular.

2. Consent Management UI

Under DPDP, consent must be:

• Informed (Rule 3)

• Specific and granular

• Unambiguous & freely given

• Recorded with a verifiable audit trail

Product role:

• Design equal ‘Accept / Reject’ options for cookies and data sharing

• Provide toggle-based consent preference panels

• Enable one-click consent withdrawal visible and accessible

3. Child Data Flows (Rule 10)

If your product collects data from children:

• Verify the parent/guardian as an adult

• Use identity + age verification methods

• Store only after receiving verifiable consent

Risk: Failing to do this = breach of child data protection → heavy penalties

4. Automated Consent Logging & Withdrawal Audit Trails

Your backend should log:

• When consent was taken

• What version of the notice was served

• Whether withdrawal occurred

• How user preferences changed over time

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5. Cookie Banner Redesign (Rule 3 & Rule 4)

Move beyond “Accept All” popups.

Compliant design must include:

• Purpose-specific consent groups (analytics, marketing, etc.)

• Rejection option with equal visibility

• Persistent “Manage Cookies” button

• Auto-blocking of non-essential cookies pre-consent

Avoid: Dark patterns, hidden reject buttons, or cookie walls

6. Grievance Flow Integration (Rule 14)

Your UI/UX must link to:

• Grievance redressal form

• Data Protection Officer (DPO) contact

• Consent complaint channel

• Response turnaround time (≤ 90 days)

Build this as a native section under “Privacy Help” or “Account Settings.”

7. Data Retention & Erasure Triggers (Rule 8)

Build product logic that:

• Automatically purges data after the stated purpose is complete

• Triggers retention check for inactive users (3 years+)

• Logs every erasure and notifies users (if applicable)

Integrating a Consent Manager: A Scalable Path

For PMs managing:

• Multiple user journeys

• Cross-platform products (web, app, kiosks)

• Multilingual users

→ Integrate a DPDP-certified Consent Manager.

Benefits:

• Seamless interoperability

• Centralised preference syncing

• Verified audit logs

• Regulatory peace of mind

Blutic’s Consent Layer makes it easy to plug in these features without slowing down your sprint velocity.

Privacy as a Product Differentiator

As a Product Manager in 2026, your roadmap is no longer just about features it’s about trust. DPDP puts privacy at the heart of design and gives you the opportunity to:

• Build loyalty through transparency

• Boost activation by respecting user choice

• Avoid compliance panic by planning now