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.

The DPDP Act mandates that customer consent must be freely given, specific, informed, unambiguous, and verifiable.

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

The Challenge: Offline Data, Untrackable Consent

BFSIs often fall short: paper forms can be mishandled, verbal consent is not recorded, and there’s no reliable system to digitally link consent to a specific customer record.

A Practical Approach to DPDP-Compliant Offline Onboarding

1. Agent-Friendly Mobile Consent Interfaces

Equip agents and branch staff with mobile tools that allow for secure, assisted digital consent capture with timestamped, verifiable consent logs.

2. SMS/WhatsApp-Based Digital Consent Confirmation

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

Aadhaar-based eKYC (OTP or biometric) and IVR systems that read privacy notices in local languages.

4. Centralised Consent Management Dashboard

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