A consent management platform is software a Data Fiduciary uses to request, record and honour consent for its own processing — presenting the notice, capturing the consent with its purpose and language, storing an auditable record, and propagating a withdrawal so processing actually stops. It is an operational tool, distinct from the statutory Consent Manager role defined in the Act.
The test of a CMP is not whether it can display a banner. It is whether a withdrawal recorded in it reaches the downstream systems that hold the data. Where withdrawal is only a status flag, consent is being logged rather than managed.
A CMP should also bind each consent record to the version and language of the notice the person actually saw, so you can show what was agreed rather than assert it.
General information about the DPDP Act, not legal advice. Obligations depend on your circumstances.
Dinkar Singh — Dinkar covers privacy engineering at ProtectComply — discovery, consent propagation and the evidence trail behind them.
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