Subikshaa Pradeep

Recovery Agents and their engagement : As per the RBI guidelines, Banks and Financial Institutions ('FI') can appoint external recovery agents to recover loans from defaulting customers. The recovery agents should be selected with utmost care, and their track record should be carefully scrutinized. They should be given proper training and guidance to ensure that they do not violate any law or misbehave with the customers.

Consent, as we note, is the primary basis for processing personal data under India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the Draft Digital Personal Data Protection Rules, 2025 (Draft Rules) released for public consultation earlier this year. The DPDP Act also introduces a unique and innovative method of managing consents by Data Principals (or Data Subjects, as referred to in global context) i.e. by appointing a consent manager for this purpose – guardians of the consent.

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