The DPDP Audit Tool
Compliance for Loyalty Program Consent Audit
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Loyalty Program Consent Audit
Liability Check

Your loyalty program collects rich customer data – from purchase history to spending patterns and preferences. Under the DPDP Act, every piece of this data requires explicit, granular consent, or you risk penalties up to ₹250 Crore.

Why Loyalty Program Consent Audit is at Risk

Loyalty programs are data goldmines, but they're also huge DPDP liability zones. Collecting **purchase history, browsing data, and demographic information** for 'better offers' without specific, revocable consent for each purpose is a direct violation. The DPDP Act mandates that consent for promotions must be separate from consent for program enrollment. Your current member journey, from sign-up to redemption, must clearly delineate what data is collected, why, and how it's used, allowing members to **withdraw consent easily for specific data processing activities** like targeted advertising or profiling. Think of your D-Mart or Starbucks app – every data point collected needs a verifiable audit trail of consent.

Common Violations

  • 1.Bundling consent for loyalty program enrollment with consent for targeted marketing, profiling, or sharing data with partners (e.g., 'agree to terms to join' covers everything).
  • 2.Failing to provide granular options for members to withdraw consent for specific data uses, such as personalized recommendations or SMS promotions.
  • 3.Retaining customer purchase history and behavioral data for profiling purposes long after the member has become inactive or withdrawn consent.

The Immediate Fix

Immediately audit your loyalty program's sign-up flow and member portal to ensure consent for each data processing activity (e.g., personalized offers, SMS marketing, partner sharing) is distinct and granular. Implement a clear, accessible mechanism for members to review and withdraw consent for specific data uses, not just the entire program.

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Projected Compliance Deadline: Immediate