Introduction
Every time a person clicks “I agree” on a website, downloads an app or opens a bank account, a separate act of consent may be given to an organisation processing that person’s personal data. Until recently, there has been no mechanism under Indian law through which an individual could manage, in one place, the consents given to different organisations, including reviewing and withdrawing those consents.
The Digital Personal Data Protection Act, 2023 (“DPDP Act”) seeks to address this fragmentation by creating a new regulated intermediary: the Consent Manager. A Consent Manager is intended to act as a single point of contact through which a Data Principal can give, manage, review and withdraw consent through an accessible, transparent and interoperable platform. Section 2(g) of the DPDP Act defines a Consent Manager as a person registered with the Data Protection Board of India (“Board”) for this purpose.