Why Consent Should Be Treated Like Configuration, Not Content

On most websites and apps, consent is still handled as content static checkboxes, pop-up modals, or generic banners with an “Accept” button and a hidden “Reject” link. But under the Digital Personal Data Protection Act (DPDPA), 2023, this outdated approach falls short of compliance.

Consent is no longer just a statement in a privacy policy it is now a dynamic system state. Like any other configurable setting, it must be manageable, traceable, revocable, and aligned with the user’s intent.

What DPDP Expects: A Technical View of Consent

The DPDP Rules, 2025 especially Rules 5 to 9 and Rule 13 require businesses to:

• Collect consent that is free, specific, informed, and unambiguous

• Associate consent with specific purposes

• Allow consent to be withdrawn at any time

• Maintain verifiable, timestamped logs

• Ensure consent is not bundled or forced

• Respect user-initiated revocation requests across systems

These are not front-end design requirements. These are system-level capabilities.

Why Static Consent Fails

When businesses treat consent as static content:

• It becomes difficult to track or audit consent

• Consent cannot be updated or withdrawn across systems

• Users lose control over how their data is processed

• Backend systems may continue data processing long after consent was revoked

• There is no reliable way to demonstrate compliance

Under Section 33 of the DPDP Act, each failure can result in a penalty of up to ₹250 crore per violation.

Consent as Configuration: A Better Model

Consent should be handled like a configurable system state, similar to notification preferences or access permissions. That means:

• Consent is managed via backend APIs and databases

• Each consent action is tied to purpose, notice version, and timestamp

• Consent is revocable through a user dashboard or API trigger

• Logs are accessible and exportable for audit purposes

• Systems respect changes in consent state in real-time

This makes your data privacy infrastructure resilient, scalable, and compliant.

Key Features of a Configurable Consent Architecture

1. Consent APIs – To update, revoke, and retrieve consent status

2. Versioned Notices – Tie each consent to the notice the user saw

3. Purpose Binding – Consent is linked only to the specified purposes

4. Time-Based Expiry – Add refresh timelines based on processing goals

5. Audit Logging – Maintain detailed logs for regulators and users

Example: Consent to Receive Emails

In a static setup:

• User checks a box

• Email is sent indefinitely

• No revocation system exists

In a configurable setup:

• Consent is stored with timestamp, purpose, and notice version

• Backend email engine checks the consent API before sending

• User can withdraw consent anytime, disabling future emails

Why It Matters in India’s DPDP Context

The Data Protection Board of India can request:

• Proof of when and how consent was collected

• Logs of withdrawal requests

• Clarification on purposes tied to consent

• System-level safeguards for enforcement

Only a configurable approach to consent can support this level of accountability.

How Blutic Helps

Blutic supports Indian businesses in building DPDP-compliant consent infrastructure by providing:

• Modular Consent and Cookie Management Tools

• APIs for revocation, modification, and purpose-based logging

• Version-controlled Privacy Notice binding

• Consent dashboards for users and compliance teams

• Real-time alerts for consent breaches and lapses

We help you treat consent like infrastructure, not interface copy.

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As the DPDP Act becomes enforceable in 2026, businesses must move beyond superficial compliance. A static checkbox won’t save you from regulatory action but a configurable, audit-ready system might.

Consent is not just about legal checkmarks. It’s about giving users control, respecting rights, and ensuring trust all of which require consent to be treated like configuration, not content.