Not necessarily. The DPDP Act recognizes that certain processing activities are necessary even without consent. Under Section 7, organizations can process personal data for legitimate uses such as fraud prevention, detecting or investigating offences, and maintaining information security.
This isn't a blanket exemption from the rest of the Act. Organizations must still ensure the processing is proportionate, limited to its intended purpose, and supported by appropriate security safeguards. Where consent isn't the legal basis, it's still important to maintain clear records demonstrating why the data was processed under the legitimate-use provision.
Explore the miniOrange Consent Management Platform.
