Q7 - How does DPDPA ensure neutrality of Consent Managers so they do not secretly favor large corporations?
Answer
- Consent Managers must be independent and neutral — they cannot favor one Data Fiduciary over another.
- They are prohibited from designing interfaces that “nudge” individuals toward accepting certain consents.
- Their neutrality is monitored through registration conditions (Schedule I) and oversight by the Data Protection Board.
Example
If a Consent Manager’s dashboard shows ABC Bank’s requests with a green “Yes” button but XYZ Bank’s with a grey “No” button, the Board can penalize it for bias.
Neutrality ensures that Consent Managers serve individuals first, not corporations.