What Fintechs Need to Rethink After GFF: 5 Data Governance Blind Spots That Demand Attention

India’s Digital Personal Data Protection Act (DPDPA 2023) is shaping the country’s digital economy with clear objectives: to protect personal data while fostering a future-ready framework that supports business innovation.

For fintechs, which sit at the intersection of data, technology, and trust, privacy and security are non-negotiable principles. Compliance is no longer just regulatory; it is a business advantage, empowering customers and building trust.

At Day 2 of the Global Fintech Festival (GFF), experts from MeitY, SBI, LIC, and the PCI Security Standards Council explored how fintechs can translate the Digital Personal Data Protection Act (DPDPA) into action. The discussion, moderated by Ms. Deepti Anand Laxmeshwar, Data Protection Officer @ Axis Bank, delivered valuable insights but also sparked deeper questions, urging the audience to think beyond compliance checklists.

Here’s a look at five key discussion points that remain open, and how fintechs can address them to stay ahead on the path to DPDPA compliance

1. Balancing Compliance and Customer Experience

Fintechs face a fundamental tension: the DPDPA demands explicit consent, transparency, and purpose limitation, while digital financial products thrive on speed, convenience, and personalization. Adding regulatory layers risks slowing down user journeys, frustrating customers, or reducing the adoption of new services.

Panelists acknowledged this friction and the need for a clear roadmap for scaling privacy-first design across millions of users and multiple touchpoints. The question remains: how can fintechs ensure compliance without compromising customer experience?

Perspective: Privacy can be a feature rather than a friction point. Technology and tooling that orchestrates consent across customer journeys and integrates with marketing and analytics stacks can help fintechs meet regulatory obligations while keeping interactions smooth - a capability that platforms like Privy provide.

2. Data Protection at Scale

Tracking consent in real time across millions of customers, partner platforms, and third-party ecosystems is a monumental challenge. Many institutions still rely on legacy IT systems or fragmented databases, making it difficult to verify whether data usage aligns with consent at any given moment.

To ensure consent management, fintechs will need to leverage auditable, scalable systems to reconcile consent across complex environments. Without robust solutions, firms risk both regulatory penalties and erosion of customer trust .

Perspective: Centralized Consent Governance Platforms can map consent to actual data usage, trigger alerts for mismatches, and provide full audit trails. By automating these workflows, fintechs not only reduce compliance risk but also strengthen customer confidence, a critical differentiator in a competitive market.

3. Data Mapping and Security

Securing data “in motion” and “at rest” is critical for compliance, yet many fintechs struggle with visibility across sprawling applications, processes, and vendor systems. Mapping, classifying, and linking data flows to business processes are complex tasks that are foundational to reporting, breach management, and privacy audits. This makes it challenging for fintechs to operationalize comprehensive data governance at scale in multi-vendor ecosystems.

Perspective: Starting with data discovery and classification, then integrating automated monitoring and compliance workflows, aids in demonstrable compliance and real control. Platforms that consolidate mapping, monitoring, and breach alerting allow fintechs to maintain a real-time view of sensitive data, ensuring both regulatory compliance and operational readiness.

4. Fiduciary vs. Processor: The Vendor Accountability Test

Under the DPDPA, Data Fiduciaries determine how data is processed, while Data Processors act on their behalf. In practice, fintechs often perform both roles, collecting, processing, and sharing data across a vast ecosystem of banks, NBFCs, technology partners, and service vendors. This overlap creates blurred lines of responsibility and significantly expands the risk surface.

The panel revisited the definitions of fiduciary and processor but did not fully address the harder question of how fintechs can prove accountability when data moves through a network of third-party systems.

The burden of proof under DPDPA lies squarely with the fiduciary. When something goes wrong, "We outsourced it" will not hold up before an auditor or adjudicatory authority. Fintechs must be able to demonstrate, with evidence, that their processors and even their processors’ processors are compliant, auditable, and governed through both contractual and technical controls.

This shifts compliance from documentation to demonstrable assurance. It is no longer enough to sign data protection addendums. Fintechs must build trusted networks of third parties with verifiable security practices, tighter contractual SLAs, and technology-led enforcement of obligations.

Perspective: Maintaining a role registry that details fiduciary and processor responsibilities across products, services, and partners is essential, but it is only the starting point. Fintechs should also map scenarios where joint fiduciary responsibility may apply and deploy systems that enable automated vendor oversight, evidence trails, and continuous monitoring.

In a privacy audit, what will matter most is not the policy but the proof

5. Trust Capital: Fintechs as Gatekeepers of India’s Digital Finance Ecosystem

Fintechs don’t just process data, they broker trust. As digital intermediaries between consumers, banks, and regulators, their systems, ethics, and transparency directly influence how much confidence India’s financial ecosystem commands.

The DPDPA has made that trust quantifiable. It’s no longer an abstract virtue; it’s trust capital - an asset that can be earned, measured, and lost. Each consent honored, each breach prevented, and each purpose mapped transparently adds to that capital.

At GFF, panellists agreed that compliance is a prerequisite for credibility, but few explored how fintechs can convert privacy compliance into long-term trust equity - the kind that makes them preferred partners for large BFSI institutions.

To serve as true gatekeepers of trust, fintechs must prove not only that they’re compliant but that they can be continuously accountable, demonstrating, in real time, how data is handled, shared, and secured across the ecosystem.