Alerts & Updates 13th Aug 2026

The Indirect Collection Dilemma: How to Fulfil Consent Requirement?

Authors

Abhay JoshiPartner | New Delhi | Noida
Ravisekhar NairPartner | Bengaluru
Aayushi SharmaPrincipal Associate | New Delhi | Noida
Akash Gulati
Akash GulatiAssociate | New Delhi | Noida

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Consent-based processing is at the core of India’s new personal data protection framework. That said, the DPDP Act, 2023 and DPDP Rules, 2025 present a significant operational dilemma for indirect data collection, where transacting customers provide details of third parties who are not present to give prior consent.

In this primer, we examine how processing third-party personal data in scenarios like e-commerce gifting, cab bookings for relatives, etc. may pose compliance problems for businesses, and why businesses must evaluate their operational models before full enforcement in May 2027.

Read the update here

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