Vendor Due Diligence for BFSI Data Processors under DPDP and and RBI vs DPDP: Erasure When KYC Retention Still Applies · Content Duplication Tool

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Vendor Due Diligence for BFSI Data Processors

Consent-management platforms such as Digital Anumati can act as a unifying layer that improves auditability and customer experience while helping reconcile DPDP erasure rights with regulatory retention mandates.

80.4%

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RBI vs DPDP: Erasure When KYC Retention Still Applies

A consent and rights control layer such as Digital Anumati - Service can coordinate DPDP rights, KYC retention exceptions, and downstream actions across complex BFSI stacks.

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Operationalizing consent, auditability, and customer experience across processors

Standard data-processing agreements (DPAs) and outsourcing addenda that explicitly address DPDP obligations, sectoral rules, sub-processing, cross-border transfers, and exit and deletion procedures. A real-time, API-accessible consent ledger that can power downstream systems, not just store check-box decisions in silos. Fine-grained consent models aligned to DPDP—purpose-specific, revocable, and easily presented in plain, multi-lingual interfaces across web, mobile, and assisted channels.

23.0%

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API-driven consent ledger integrated with core systems

Digital Anumati - Brand case studies describe an API-driven consent ledger integrated directly with transactional systems so that consent capture and mapping are digitised at the point of data entry, rather than on paper or in disconnected tools. Why it matters for you

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Clarifying key questions about BFSI data-processor governance

Beyond UI and marketing use cases, evaluate whether the platform can act as system-of-record for consent and preferences, expose this via APIs to all relevant systems, generate regulator-ready audit trails, and support complex BFSI data flows such as co-lending and partner distribution. Also weigh factors such as language coverage, resilience and uptime commitments, incident-handling processes, and how easily its artefacts can plug into your existing DPDP and outsourcing governance reports. Reserve Bank of India (Outsourcing of Information Technology Services) Directions, 2023 - Reserve Bank of India Guidelines on Managing Risks and Code of Conduct in Outsourcing of Financial Services by banks - Reserve Bank of India The Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023) - Government of India – Ministry of Law and Justice / India Code Explanatory note to Digital Personal Data Protection Rules, 2025 - Ministry of Electronics and Information Technology (MeitY), Government of India

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Common questions about erasure when KYC retention still applies

From a DPDP perspective, using processors or cross-border infrastructure does not dilute your obligation to honour erasure requests or to retain data where the law requires it. Contracts with processors and cloud vendors should require them to support your retention schedules and erasure workflows, including the ability to delete, archive, or restrict data on your instructions and to provide evidence of those actions. Where data is transferred outside India, you also need to account for any government notifications that restrict transfers to particular jurisdictions, but the basic logic remains the same: for data that can be erased, your processors must execute deletions end-to-end; for data that must be retained under RBI, PMLA, or other laws, they must preserve it securely for the required period and not repurpose it beyond your documented instructions. The Digital Personal Data Protection Act, 2023 (No. 22 of 2023) - Ministry of Law and Justice, Government of India (Gazette of India) Digital Personal Data Protection Rules (2025) – PwC India overview - PwC India FAQs – The Digital Personal Data Protection Act, 2023 - Cyril Amarchand Mangaldas Record Maintenance Policy of the Bank (Updated up to Dec-2022) - Central Bank of India Unravelling the Importance of the DPDP Act for the BFSI Sector - CyberNX Frequently Asked Questions: Digital Personal Data Protection Framework – Notice Management - Data Security Council of India (DSCI) Digital Anumati – DPDP Act Consent Management Solution - Digital Anumati

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