DPDP Cookie Banner Guide
Implement DPDP-compliant cookie banners for Indian users. Covers tracking, analytics, and affirmative consent withdrawal requirements. Get expert help.
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DPDP Action Sheet
Use this before your next workflow goes live. It keeps the useful parts visible and turns DPDP into checks your team can actually answer.
For DPDP Cookie Banner Guide, the DPDP question is how personal data enters the workflow, where it is stored, which tools touch it, what purpose was explained, and how deletion or withdrawal will work.
1. Lead Forms
Check:
- What data are you collecting?
- Is the purpose clear at the point of collection?
- Is marketing consent separate from service communication?
- Can the user withdraw consent later?
Common mistake: one checkbox that silently covers newsletters, sales calls, partner sharing and remarketing.
2. Email and WhatsApp
Check:
- Who is on the list?
- Where did consent come from?
- Is the list imported from a vendor, event, webinar, scrape or old CRM?
- Can you prove the source of consent?
Common mistake: treating every lead as permanently marketable.
3. Ads and Retargeting
Check:
- Are pixels or ad platforms receiving identifiable user behavior?
- Are audiences built from customer lists?
- Are lookalike or remarketing audiences using personal data?
Common mistake: assuming "the ad platform handles it" means your company has no DPDP responsibility.
4. Website Analytics
Check:
- Which tools run on the site?
- Are IP address, device identifiers, session IDs or form fields being captured?
- Is analytics used only for measurement, or also for profiling and targeting?
Common mistake: installing tools first and asking privacy questions later.
5. Vendor List
Make a quick list:
- CRM
- Email platform
- WhatsApp provider
- Analytics
- Ad pixels
- Form tool
- Landing page builder
- Webinar tool
For each vendor, answer: what data goes there, why, who can access it and how deletion works.
6. This Week's Action
Map one campaign from first click to final follow-up. Mark every place personal data is collected, enriched, shared, uploaded or used for targeting.
If your team cannot answer where the data came from and where it goes next, start with a data flow map before rewriting policy copy.
Book a DPDP clarity callWant all of this handled, end to end? Sanctum is the all-in-one DPDP compliance programme behind this site: legal position, data map, gap analysis, implementation, tooling, training, readiness opinion, and breach cover under one accountable owner. How all-in-one DPDP compliance works or see the Sanctum programme.
Consent for Tracking Identifiers
DPDP treats device IDs and IP addresses as personal data when they identify an individual. Cookie banners must move beyond a simple “Okay” button. You must provide a notice that lists every tracker used and its specific purpose. This notice must be clear and separate from your general terms and conditions. If your website targets users across India, the notice must be available in English and any relevant local language listed in the Eighth Schedule of the Constitution.
Handling Third-Party Analytics
Marketing and analytics cookies often share data with third-party platforms. Under DPDP, you must disclose if these cookies send data to external processors. If your analytics tool identifies a specific user, you need a checkbox or toggle that is “off” by default. Silence or inaction is not considered consent. You must wait for the user to click “Accept” before any non-essential tracking scripts or pixels load on the page.
Notice and Withdrawal Requirements
Consent for cookies is not a one-time event. Your banner system must allow users to change their minds as easily as they gave consent. A hovering icon or a footer link should allow users to re-open their preferences at any time. Once a user withdraws consent for a specific category, such as marketing pixels, you must stop that data flow immediately. You must also ensure that the data already collected under that consent is deleted if the purpose is no longer valid.
| Tracking Type | Data Collected | DPDP Requirement |
|---|---|---|
| Essential Cookies | Session IDs, Security tokens | Notice only |
| Analytics | IP Address, User behavior | Affirmative Consent |
| Marketing Pixels | Device IDs, Ad identifiers | Specific Opt-in |
| Personalization | Region, UI preferences | Granular Choice |
| Social Plug-ins | Profile links, tracking | Third-party disclosure |
This week
Review your website’s cookie settings to confirm that the “Reject All” button is exactly the same size, color, and font as the “Accept All” button to ensure fair choice.
Now think about your work. Where does personal data enter your workflows? Where does it sit? Who else touches it?
Frequently asked questions
Does DPDP require banners for strictly necessary cookies?
Necessary cookies used for basic website security or session management do not require consent. However, you must still list them in your notice to ensure transparency about what data is collected.
Can I use banners that say 'by continuing to browse you agree'?
No, DPDP requires an affirmative action for consent. Scrolling, clicking other links, or staying on a page does not count as clear, affirmative consent for tracking.
Do I need to offer the cookie notice in local Indian languages?
The law requires the notice to be available in English and any of the 22 languages specified in the Constitution. If a user chooses a local language, your banner must support it.