DPDPA Implementation At Attestr

Build Privacy-First KYC Workflows with Consent at the Core

Attestr is designed with a consent-first architecture aligned with the principles of the Digital Personal Data Protection Act, 2023 (DPDPA). Our platform enables organizations to collect, manage, govern, and audit Data Principal consents while maintaining transparent and compliant data processing workflows.

This document explains the fundamentals of DPDPA, the different stakeholder roles defined under the law, and how Attestr implements a consent-based operating model across its products and services.

Understanding the Digital Personal Data Protection Act (DPDPA), 2023

The Digital Personal Data Protection Act, 2023 is India’s primary privacy and personal data protection legislation governing how digital personal data is collected, processed, stored, and shared.

The law establishes a framework for lawful processing of personal data while protecting the rights of individuals and enabling organizations to operate trusted digital services responsibly.

DPDPA applies to:

• Personal data collected digitally
• Digitized offline personal data
• Processing within India
• Processing outside India involving goods or services offered in India

The Act focuses on:

• Lawful and transparent processing
• Consent-based data handling
• Purpose limitation
• Data minimization
• User rights and grievance mechanisms
• Accountability of organizations handling personal data

The notification of the rules triggers a phased implementation timeline for compliance.

• November 13, 2025: The Act officially came into force, establishing the baseline rights, duties, and the Data Protection Board of India (DPBI).
• November 14, 2026: Frameworks for registered Consent Managers will become fully active.
• May 13, 2027: Full enforcement begins, meaning businesses and organizations have until this date to achieve complete operational compliance to avoid penalties

Key Principles of DPDPA

Consent-Driven Processing

Organizations must obtain free, specific, informed, unconditional, and unambiguous consent from individuals before processing their personal data unless processing falls under certain legitimate use cases defined by law.

Purpose Limitation

Personal data should only be processed for the purpose communicated to the Data Principal during consent collection.

Data Minimization

Only necessary personal data required for the intended purpose should be collected and processed.

Accuracy of Data

Organizations are responsible for ensuring personal data remains accurate and updated where necessary.

Storage Limitation

Personal data should not be retained indefinitely beyond the required lawful purpose.

Accountability

Entities processing personal data are responsible for implementing security safeguards, auditability, and compliance controls.

Roles Defined Under DPDPA

Data Principal

The individual to whom the personal data relates.

Examples: Customer, Employee, Candidate, Vendor, End User

The Data Principal has rights relating to:

• Access to information
• Consent withdrawal
• Grievance redressal
• Correction and erasure of data

Data Fiduciary

An organization that determines the purpose and means of processing personal data.

Examples: Banks, Employers, Fintech platforms, Insurance companies

The Data Fiduciary is responsible for:

• Collecting valid consent
• Maintaining compliance
• Protecting personal data
• Ensuring lawful processing

Data Processor

An entity that processes personal data on behalf of the Data Fiduciary.

Examples: Cloud providers, Verification platforms, Consent management providers, SaaS infrastructure vendors

Data Processors act based on instructions provided by the Data Fiduciary.

Consent Manager

A Consent Manager is an interoperable platform that enables Data Principals to provide, manage, review, and withdraw consent through an accessible and transparent mechanism.

Attestr’s consent infrastructure is designed to support organizations in implementing Consent Manager-style workflows for enterprise-grade consent governance and lifecycle management.

Consent is the Foundation of Every Workflow at Attestr

Attestr is fundamentally designed around a consent-driven operating model. Before personal data is processed, verified, shared, or consumed, consent can be captured, recorded, validated, and audited through the platform.

Our architecture enables businesses to implement privacy-by-design principles across digital onboarding, verification, background checks, KYC workflows, and consent-driven data processing systems.

How Attestr Implements DPDPA Principles

Consent Registration

Organizations can register and maintain structured consent records including - Consent purpose, Consent validity, Consent mode, Consent source, Privacy policy version, Data categories, Audit metadata. Every consent record is timestamped and traceable.

Hosted Consent Collection Pages

Attestr provides hosted Consent-as-a-Service pages that enable organizations to collect user consent without building their own infrastructure. Features include - Custom branding, Custom domains, Mobile-friendly workflows, OTP verification, Audit logging, Multi-purpose consent collection.

Consent Lifecycle Management

Attestr enables centralized management of different consent lifecycle status which includes Active consents, Revoked consents, Expired consents, Consumed single-use consents. Every status transition is recorded with a complete audit trail.

End User Transparency

Organizations can enable self-service portals where Data Principals can view Active consents, Review consent history, Monitor consent usage, Withdraw consent, Access audit records. This improves transparency and strengthens trust.

Auditability & Compliance Readiness

Attestr maintains detailed lifecycle event tracking for every consent transaction including - Consent creation, Updates, OTP verification, Consent usage, Revocation events, Expiry events, API activity, Webhook events. Organizations can export complete consent archives for audits, investigations, and compliance evidence.

API & Webhook Driven Infrastructure

Attestr provides secure APIs and webhook integrations for - Consent creation, Consent validation, Consent status updates, Revocation handling, Workflow automation. This enables seamless integration into enterprise systems and digital onboarding workflows.

DPDPA Use Cases Supported by Attestr

KYC & Customer Onboarding

Capture and govern user consent before identity verification and onboarding workflows.

Background Verification

Collect candidate consent prior to employment verification and document processing.

Financial Services

Enable consent-driven processing for fintech, lending, insurance, and regulated workflows.

Consent Governance Platforms

Build centralized consent management and compliance systems across business units.

Attestr follows privacy-first engineering principles including - Consent-first processing, Role-based access controls, Audit logging, Encryption controls, Purpose-linked processing, Traceable event histories, Configurable retention policies. Our objective is to help organizations operationalize DPDPA compliance through scalable, developer-friendly infrastructure.