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Q7 - What is the relationship between a Data Fiduciary and a Consent Manager — is one more powerful than the other?

Answer
  • A Data Fiduciary is the organization that collects and processes personal data (e.g., banks, insurers, e-commerce platforms).
  • A Consent Manager is an independent intermediary that helps Data Principals (individuals) grant, manage, or withdraw consent.
  • The Fiduciary cannot override the Consent Manager. If an individual withdraws consent through the Consent Manager, the Fiduciary must honor it.
Example

ABC Bank (Data Fiduciary) wants to market personal loans.
XYZ Consent Hub (Consent Manager) lets Krishna withdraw consent for marketing.
Once withdrawn, ABC Bank must immediately stop sending offers, even if its own systems still list Krishna as opted-in.

So, the Consent Manager doesn’t have more “power,” but it acts as a check on Fiduciaries, ensuring that individual rights are enforceable.