SCENARIO S01 · PROCESSORS & EVIDENCE
A SaaS app cannot show which notice a customer saw when consent was recorded. What should be created?
IN PLAIN ENGLISH
Why you are seeing this step
This field note uses one realistic decision to separate the official source, an editorial interpretation, a practical option, evidence to keep, and any uncertainty that still depends on your facts.
Educational only, not legal advice. Source status is dated 13 May 2027; inspect the official links below before relying on it.
BEST NEXT STEP
Preserve the notice version, affirmative event, purpose and operational follow-through.
Build a consent receipt that can be interpreted later, not just a database flag.
WHY THE OTHER INSTINCTS MISS
Preserve the notice version, affirmative event, purpose and operational follow-through.
Correct. Act section 6(10) places the burden of proving notice and consent on the Data Fiduciary in a proceeding.
Keep only a boolean “consented” field.
A boolean cannot show the notice, purpose, wording, language or event that produced it.
Ask the customer to remember what the screen said.
The proof obligation cannot sensibly depend on a person reconstructing the product interface later.
BUILD THIS EVIDENCE
Immutable notice version, purpose identifier, event timestamp and downstream instruction log.
This artefact supports review. It does not certify compliance or replace advice on your facts.
- Guidance type
- legal requirement
- Pinpoint
- Act ss. 5 and 6(10); G.S.R. 843(E)
- Reviewed
- 2026-08-30
- Change note
- Status and pinpoint reviewed against the official Act, final Rules, commencement notification and corrigendum for this educational website.
OFFICIAL SOURCE TRAIL
Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023) ↗
Definitions and specified machinery provisions are operative; most substantive duties and rights are notified for later commencement. Check each scenario's status record.
Act s. 1(2); provision-specific section pinpointsDPDP Act commencement notification G.S.R. 843(E) ↗
Appoints immediate, one-year and eighteen-month commencement cohorts for the Act.
G.S.R. 843(E), clauses (a)–(c)