A Project by Meridian Bridge Strategy
Compliance Guide

DPDP Compliance for Neobanks and Digital Banks

Neobanks process Video KYC, UPI logs, and alternative credit data. Learn how Indian digital banks must manage DPDP compliance and partner data sharing.

Discuss this page with an LLM

ChatGPT Claude Gemini Perplexity

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 Compliance for Neobanks and Digital Banks, 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.

Check my data flow

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 call

Now think about your work. Where does personal data enter your workflows? Where does it sit? Who else touches it?

Frequently asked questions

How should Neobanks handle Video KYC data under DPDP?

Video KYC records contain biometric and identity data. Digital banks must encrypt these files and ensure the consent notice explicitly covers the storage of video and audio for identity verification purposes only.

Is a Neobank responsible for data shared with a sponsor bank?

Yes, the Neobank must clearly identify the sponsor bank as a third-party recipient in the consent notice. The contract between the Neobank and the sponsor bank must define which entity is the Data Fiduciary for each specific dataset.

Can Neobanks use transaction data for automated credit limit increases?

Using transaction history for credit profiling is a separate purpose from simple payment processing. You must obtain specific consent for credit scoring and allow users to opt out of this specific use without losing access to core banking features.

Book clarity call