Your existing customer base was collected under old rules. Before enforcement, every one of those records needs either a proper notice or fresh consent.
The legacy data problem
You have years of customer data collected under one working assumption: they signed up, so I can email them. DPDP replaces that assumption, and it splits your existing base into two buckets that need different treatment.
Bucket one: consent you can stand behind
Where the person clearly agreed, the Act requires you to send them a notice as soon as reasonably practicable: what data you hold, why you process it, and how to withdraw. Processing can continue for the original purpose until they withdraw. The notice is the compliance act, and the proof that you sent it is the evidence.
Bucket two: contacts with no clean consent
Bought lists. Scraped contacts. Pre-ticked checkboxes. Implied opt-ins from a trade show five years ago. These records need fresh, specific consent before enforcement.
Contacts who stay silent after your reminders leave the marketing base. Budget for that shrinkage now: a smaller consented list outperforms a large list that carries a ₹250 crore exposure.
How to run the campaign
- Send a plain-language email explaining DPDP and why you are asking.
- Offer separate checkboxes per purpose: marketing, product updates, data sharing.
- Make yes easy and no equally easy. Skip the legalese.
- Track every response. The log is your proof.
- Send two or three reminders, then stop processing the silent records in bucket two.
Response campaigns across a base of thousands take months, and consent rates run low. Teams that start a year out finish calm. Teams that start in the final quarter lose the list.
Your recapture plan
Segment the base into the two buckets: clean consent and everything else.
Draft the notice for bucket one.
Draft the per-purpose consent form for bucket two.
Set the reminder schedule and the stop date.
Build the proof log before the first email goes out.
Next step
Recapture is one lane of the full programme. See where it fits and what the rest costs.
See the compliance cost ladder →Related reading
Written by Sushant Pasumarty
DPDP consultant. Founder, Meridian Bridge Strategy. This page began as field notes from live client work.