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Consent Governance

The Consent Governance Module (CGM) provides the backbone for handling and orchestrating consents collected from Data Principals. It aligns with the Digital Personal Data Protection Act (DPDPA), 2023 and enables organizations to manage, review, filter, and generate actionable insights from consents in a secure, interoperable way.

1. Objectives​

  • Collect, store, and manage consents in compliance with DPDPA.
  • Allow Data Principals to view, review, and withdraw consent easily.
  • Enable Data Fiduciaries to track consent status and obligations.
  • Provide auditable records and insightful analytics for compliance and business intelligence.

2. Core Features​

FeatureDescription
Consent CollectionCapture free, specific, informed, and unambiguous consent from Data Principals. Support multilingual notices and clear affirmative actions.
Consent Review & StatusDisplay current status of consent (active, withdrawn, expired, pending). Show data elements, purpose, and time stamps.
Consent WithdrawalProvide easy mechanisms to withdraw consent with comparable ease to giving it. Trigger automatic downstream actions.
Filtering & SegmentationFilter consents by purpose, geography, age group, or data element to identify patterns or compliance gaps.
Analytics & InsightsGenerate dashboards for opt-in rates, withdrawal trends, purpose-level consent, and retention periods.
Consent Artefact GenerationAutomatically generate digitally signed artefacts as proof of consent/withdrawal, including audit trails.
APIs & InteroperabilityProvide REST/GraphQL APIs to integrate with Consent Managers or third-party systems. Support standard formats for portability.
NotificationsNotify Data Fiduciaries and Data Principals of consent changes, expirations, or regulatory updates.

3. Data Model Overview​

  • Data Principal ID – Unique identifier (UUID or pseudonymous ID).
  • Consent ID – Unique consent record identifier.
  • Purpose/Processing Activity – Scope of consent.
  • Data Elements – List of personal data fields covered.
  • Consent Status – Active / Withdrawn / Expired / Pending.
  • Timestamp & Validity – When consent was given, updated, or withdrawn.
  • Artefact Metadata – Hash of consent artefact, storage location, signature.

4. Governance Workflow​

  1. Capture – Present a clear and compliant consent notice to the Data Principal.
  2. Store – Save consent details securely with cryptographic hashing for integrity.
  3. Monitor – Continuously track consent status and expiration periods.
  4. Act – When consent is withdrawn or expires, automatically trigger data erasure or restricted processing.
  5. Report – Generate dashboards, compliance reports, and consent artefacts for audits.

5. Integration Points​

  • Consent Managers – Register and sync consent records with Board-registered Consent Managers.
  • Data Fiduciary Systems – Link with CRM, data warehouses, or transaction systems to enforce consent status.
  • Breach Management – Provide evidence of valid consent in case of regulatory inquiry or breach.
  • DPIA Module – Feed aggregated consent data to Data Protection Impact Assessments for risk scoring.

6. Privacy & Security by Design​

  • Encryption – All consent data encrypted at rest and in transit.
  • Immutable Audit Logs – Maintain non-repudiable consent trails (blockchain optional).
  • Role-Based Access Control (RBAC) – Limit who can view or modify consent records.
  • Data Minimization – Store only necessary consent metadata, link to secure vaults for sensitive details.

7. Example Use Cases​

  • Healthcare App – Patients give consent for teleconsultations and can later revoke for research sharing.
  • E-commerce Platform – Customers opt-in to marketing emails but can withdraw while retaining purchase consents.
  • Government Benefits Portal – Citizens grant consent to share eligibility data with multiple agencies through a unified Consent Manager.

8. Implementation Recommendations​

  • Microservices Architecture – Decouple the consent governance module for scalability.
  • API-First – Provide CRUD endpoints for consents and artefacts.
  • Event-Driven – Use message queues or change streams to propagate consent changes across systems.
  • Testing & Auditing – Simulate withdrawal scenarios and audit logs periodically.
  • Community Standards – Adopt open standards like ISO/IEC 27560 for consent records.

9. Output Artefacts​

  • Consent Artefact – Digitally signed proof containing: Data Principal ID, purpose, timestamp, Data Fiduciary, and hash.
  • Consent Summary Dashboard – Purpose-wise or region-wise consent metrics.
  • Compliance Report – Exportable CSV/JSON/Encrypted files for regulatory audits.