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A seven-minute checklist before Section 33 exposure lands

8 October 2026

A seven-minute checklist before Section 33 exposure lands

You have seven minutes between calls. Here is what is worth checking right now, regardless of which tools your store runs or whether you have touched DPDP Act compliance at all yet. This is a checklist to run against your own store, not a pitch for any particular way of doing it.

1. Do you actually know where customer data goes

Before anything else, write down every tool that touches a customer's name, phone number, email, or address once they interact with your store. The usual list for an Indian D2C Shopify store includes an ad pixel like Meta Pixel, an email tool like Klaviyo, a WhatsApp business solution provider for order updates, a 3PL for delivery, a reviews app, a payment gateway, and GST invoicing tooling. If you cannot name this list from memory in under a minute, that is the actual starting point, not a notice, not a banner, this list.

2. Is your privacy notice honest about that list

A privacy notice that says "we may share data with third parties as necessary" without naming who those parties actually are and what they actually do is not doing its job. Check whether yours names the real tools from your list above and the real purpose each one serves. If it reads like a template nobody updated after the tools changed, it needs attention.

3. Is there an actual consent banner, and does it log answers

Having a cookie or consent-style banner on the storefront is one thing. Having a record of which shopper clicked what, and when, is a separate thing, and it is the part that matters if anyone ever asks what a specific shopper agreed to. Check whether your current setup, whatever it is, keeps that record anywhere retrievable, or whether the banner just disappears into the page with nothing kept behind it.

4. Can a shopper withdraw consent as easily as they gave it

Giving consent is usually one click. Check whether withdrawing it is anywhere close to that easy, reachable from roughly the same place the original consent was collected. If withdrawal means hunting for a support email and waiting days for a reply, that asymmetry is a gap worth closing before a shopper tests it.

5. Do you have a working process for access, correction, and deletion requests

A shopper is allowed to ask what data you hold on them, ask you to correct it, or ask you to delete it. The Rules allow a response window of up to 90 days for these. Check whether you have anywhere to log the date a request came in, and whether anyone on your team actually knows what to do with it when it does, including going into each connected tool, your ESP, your WhatsApp provider, your 3PL, to action it there, since none of those propagate a deletion automatically on their own.

6. Do you have a breach record process, even a basic one

If something ever goes wrong with how customer data was handled, a countdown to notify starts, and a merchant has to act on it using their own tools and contacts. Check whether you have even a simple record, a document, a log, anywhere, that would let you note the date something happened and track what you did about it. Most stores have nothing here at all, which is itself worth knowing before it becomes urgent.

What this checklist is actually testing for

None of these six questions require a lawyer to answer honestly. They require someone sitting down for seven minutes with their own store open and checking what is actually true today, rather than what they assumed was true. Most founders who run through this list for the first time find at least three gaps, which is normal and fixable, not a reason to panic.

These six questions map directly onto what Consent Jet's four functions are built to cover: finding the real processor list, publishing a notice built from what the scan finds, running a consent banner that logs proof both ways, and giving you a place to receive and track rights requests and breach records against their clock.

A seven-minute checklist before Section 33 exposure lands | Consent Jet