Ensuring DPDP Compliance in Offline Data Collection - BFSI Article Series Part 2

The Digital Personal Data Protection (DPDP) Act is forcing businesses across India to rethink how they collect, store, and process customer data. For most BFSI institutions, that means building digital-first journeys — it also means addressing the massive chunk of customer onboarding that still happens on paper.

Whether it’s an account opening form submitted at a branch counter, or loan application details collected by a field agent, offline data collection is deeply entrenched in BFSI operations. But here’s the challenge: the DPDP Act applies equally to all digital personal data — including data that was physically collected and then digitised.

And that’s where problems begin.

The DPDP Act mandates that customer consent must be freely given, specific, informed, unambiguous, and verifiable. It also requires businesses to ensure that data processing is based on clear purpose, and that consent trails are securely maintained for audits, redressal, or breach notifications. None of this is straightforward in a paper-based flow.

So how can BFSI companies maintain DPDP compliance while continuing to operate agent-led, branch-based or semi-digital onboarding journeys?

Let’s break it down.

The Challenge: Offline Data, Untrackable Consent

In a typical offline flow, customers fill out a physical form. An agent or branch staffer submits it. The document may be scanned and stored. But what about the consent trail? Was the customer shown a privacy notice? Was their consent specific to the use case? Can the institution prove it later?

Here’s where BFSIs often fall short:

• Paper forms can be mishandled, lost, or tampered with.
  
• It’s hard to ensure that every customer — especially those in rural areas or with low digital literacy — has understood the privacy notice.
  
• Even if verbal consent is obtained, it’s often not recorded, timestamped, or verifiable.
  
• There’s no reliable system to digitally link consent to a specific customer record.
  

These gaps aren’t just procedural inefficiencies — under the DPDP Act, they are compliance risks.

A Practical Approach to DPDP-Compliant Offline Onboarding

While the DPDP Act expects modern, verifiable consent, it does not mandate that every customer interaction must happen on a smartphone. This gives BFSIs flexibility — but they must design physical journeys that digitally document consent in real time, ensure accessibility, and enable centralised compliance tracking.

Here’s how.

1. Agent-Friendly Mobile Consent Interfaces

Equip agents and branch staff with mobile tools that allow for secure, assisted digital consent capture — even in offline settings. These interfaces should:

• Display multilingual privacy notices using pre-recorded audio or visual formats
  
• Support Aadhaar OTP, fingerprint, or face ID for identity verification
  
• Generate timestamped, verifiable consent logs linked to a customer’s CBS record

This ensures that even when onboarding is assisted, the consent is compliant and the trail is complete.

2. SMS/WhatsApp-Based Digital Consent Confirmation

If mobile or digital infrastructure isn’t available at the point of data collection, the next best solution is to follow up with a digital consent request sent via SMS or WhatsApp.

Once the customer’s basic information is collected, a secure link can be shared, allowing them to confirm consent digitally — in their own time. This consent, once completed, is recorded and linked to their application, ensuring real-time compliance without slowing down operations.

3. eKYC and IVR for Low-Literacy, Low-Tech Contexts

In geographies where smartphone access is low or literacy is a barrier, BFSIs can rely on alternative consent channels like:

• Aadhaar-based eKYC (OTP or biometric)
  
• IVR systems that read out privacy notices in local languages and record verbal consent
  

These tools make it possible to deliver a DPDP-compliant consent experience — even to customers who may not be digitally native.

4. Multilingual, Accessible Privacy Notices

Consent under DPDP must be informed — and informed consent is only possible when the customer understands the notice. This means BFSIs must provide:

• Privacy notices in the customer’s preferred language
  
• Clear, non-technical explanations of how data will be used
• Audio/video options for customers who may struggle to read
  

Given India’s linguistic diversity, institutions should ideally offer notices in at least the 22 Constitutionally recognised languages.

5. Centralised Consent Management Dashboard

No matter how or where consent is collected, BFSIs need a single platform where:

• All consent logs — biometric, OTP, verbal, or SMS-based — are stored
  
• Consent can be linked directly to customer records
  
• Withdrawal requests, updates, and breach audits can be handled quickly
  

A unified consent infrastructure allows businesses to consolidate physical and digital onboarding, and monitor compliance centrally — with complete visibility into consent history.

Why It Matters

Managing paper forms is not just inefficient — it’s risky. Physical documents can be mishandled. Consent may be assumed but not recorded. Notices may be skipped. And when the regulator asks for evidence, most institutions struggle to produce a clear, auditable trail.

By integrating digital consent capture into offline journeys — through mobile UIs, eKYC, IVR or follow-up SMS links — BFSIs can eliminate this risk while improving operational efficiency.

You don’t need to rebuild your onboarding from scratch. But you do need to retrofit it with the right compliance guardrails.

The Bottom Line

The DPDP Act doesn’t differentiate between an app form and a paper form. If the data is personal and it’s being processed digitally, you’re responsible for collecting and maintaining proper consent — no matter how the data was collected.

For BFSIs, this means that every branch, every field agent, and every form must now operate within a consent-first architecture.

Done right, this shift can help institutions stay compliant across all geographies, build trust with underserved and rural customers and future-proof their onboarding journeys.

Want to make your onboarding flows DPDP-compliant — without rebuilding everything?

Leegality’s Consent Infrastructure helps BFSI organizations collect, verify, and manage customer consent — across digital and physical journeys.

Whether you're using agents, apps, SMS, or eKYC, we help you:

• Launch multilingual, assisted consent flows;
  
• Build verifiable audit trails;
  
• Integrate consent logs directly into your CBS and CRM.
  

Sign up using the form below to book a demo and explore how Leegality can help you make your physical onboarding flows fully DPDP-compliant — without overhauling your existing processes.