Question: Are consent mechanisms implemented, recorded, and managed for all processing that requires it?
Why This Matters
Consent is a legal foundation for most personal-data processing. Verifiable consent management proves fairness, transparency, and control for data principals.
Maturity
0 — Unaware
No consent process; users auto-enrolled.
No consent process; users auto-enrolled.
1 — Ad Hoc
Checkboxes without records of acceptance.
Checkboxes without records of acceptance.
2 — Defined
Consent statements documented and logged.
Consent statements documented and logged.
3 — Managed
Withdrawal and update workflows operational.
Withdrawal and update workflows operational.
4 — Integrated
Central consent registry linked to systems.
Central consent registry linked to systems.
5 — Optimized
Dynamic consent dashboards and automated expiry handling.
Dynamic consent dashboards and automated expiry handling.
How to Level Up
| From → To | Actions |
|---|---|
| 0 → 1 | Add explicit opt-in checkboxes to all data-collection forms. |
| 1 → 2 | Log timestamp, source, and policy version for each consent. |
| 2 → 3 | Implement withdrawal and correction channels. |
| 3 → 4 | Maintain unified consent registry across systems. |
| 4 → 5 | Automate expiry alerts and self-service dashboards. |
Enablers
- People: DPO, Application Owner, Marketing Lead
- Process: Consent capture → storage → revocation
- Technology: Consent-management platform or database
Evidence
- Consent registry extract
- Withdrawal requests log
- Policy-version mapping
KPIs
- Number of consents recorded per source
- Percentage with withdrawal option verified
- Average time to honour revocation
Low-Cost / Open-Source Options (MSME)
| Purpose | Tool | Notes |
|---|---|---|
| Registry | Airtable / PostgreSQL | Track consent records |
| Web forms | Formspree / Google Forms | Capture timestamps |
| Automation | n8n | Expiry and revocation workflow |
Common Pitfalls
- No proof of opt-in
- Withdrawals ignored
- Same form reused without versioning
Compliance Mapping
| Standard | Clauses / Notes |
|---|---|
| ISO/IEC 27701 | 7.3 (Consent Records) |
| DPDP Act 2023 | Sec 7 (Consent and Withdrawal) |
| GDPR | Art. 7 |
| NIST CSF 2.0 | ID.DP-02 / GV.PO |
| NIRMATA Mapping | PD-Q05 establishes defensible consent management. |