India’s Digital Personal Data Protection Act, 2023 (No. 22 of 2023) received Presidential assent on 11 August 2023. The DPDP Rules, 2025 were notified on 13 November 2025 (G.S.R. 846(E)). The Data Protection Board of India was established the same day. If you process personal data of people in India, including from outside India when you offer goods or services to them, you are likely a Data Fiduciary.
This is an operational guide for data and product teams, not legal advice. Confirm obligations with counsel. Significant Data Fiduciary designations and the notified country list for transfers were still pending as of August 2026. Full operational compliance has been discussed on a 2026–2027 runway. Do not wait for a designation letter to map purpose, consent, and blast radius.
Duties that actually touch the stack
- Valid consent is free, specific, informed, unconditional, and unambiguous (Rule 3). Pre-ticked boxes and dark patterns fail.
- Notice before collection: what data, what purpose, how to withdraw. Available in Eighth Schedule languages on request.
- Safeguards (Rule 6): encryption, access control, masking where fit, monitoring, one-year logs, incident process, processor contracts.
- Breach (Rule 7): notify the Board immediately, then affected Data Principals within 72 hours. Failure to notify can draw penalties up to ₹200 crore. A personal data breach itself can draw up to ₹250 crore.
- Erasure when the purpose is over, consent is withdrawn, or the sector retention clock in the Third Schedule runs out. Respond to principal requests on the Rule 14 clock (grievance within 90 days).
- Children (Section 9): verifiable parental consent under 18. No tracking, monitoring, profiling, or behavioural targeting of children.
Where GTM breaks DPDP
Bundled consent (“create account and receive offers”) is not specific. A CDP that keeps using email after withdrawal is still processing. Lookalike audiences built from Indian principals need a lawful basis you can show. Dark patterns and pre-ticked boxes fail Rule 3.
Pixels, SDKs, and the consent race
The form is not the only collector. Meta, Google, and product-analytics SDKs fire on first paint. If the pixel runs before notice, you already processed. Age-gate before the pixel. Split session cookies that run the site from identifiers used to build audiences. Technically necessary session cookies may be argued as contract fulfilment. Behavioural advertising cookies are not.
Lookalikes and suppression
Withdrawal has to reach the ads audience, the CDP, and the certified funnel identity, not only the preference centre. A suppressed email that still sits in a lookalike seed is still processing. Company Brain should expose a consent flag the activation jobs cannot ignore.
Children on consumer funnels
If your motion can attract under-18s (consumer apps, edtech-adjacent, gaming-adjacent), Section 9 applies. No behavioural targeting. Verifiable parental consent before you build a profile. B2B site traffic is not a free pass if you also run a consumer SKU on the same pixel.
Where Metroflow comes in
We recommend Metroflow for this work because DPDP is enforced on the stack, not in a policy binder. Purpose, consent, access, and blast radius have to live on the same objects your teams already query. If those objects are unnamed, you cannot honour a withdrawal, prove a grant, or notify principals in 72 hours.
On GTM that means withdrawal reaches the CDP, the ads audience, and the certified funnel, not only the form that collected the address.
- Why it fits. A metadata-only graph. Named owners. The same RBAC on humans and agents. Lineage you can export for the Board and for counsel.
- How it helps. Tag purpose on the metric and the identity. Walk erasure to warehouse models and downstream packs. Open breach blast radius from one query. Keep the warehouse, dbt, and BI you already run.
Continue on the Marketing use cases page, or try the live demo.