A problem that's often less about the merchant's own practices and more about whether the SaaS platform underneath them can actually support compliant consent flows.
The Data Processor angle isn't a separate section here — it's the core of the problem, since so much of the exposure runs through the underlying platform rather than the merchant's own code.
Large aggregators run their own technology, but a significant share of e-commerce and D2C brands run on SaaS/hosted commerce platforms with limited ability to customise consent flows themselves.
Even where the underlying use case is fairly standard, the SaaS platform itself has to actually support DPDPA-compliant consent capture — this is as much a vendor question as a merchant one.
Reviewing the SaaS/hosting agreement and getting the vendor to provide compliance documentation in a clear, simplified format is often the fastest real path to closing this gap.
Marketing consent is frequently bundled with account creation, failing the specificity standard.
Third-party ad-tech and analytics SDKs create collection points product teams may not be aware of.
Logistics partners handling name, address and phone number require proper Data Processor agreements.
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