A withdrawal that reaches every partner
A lending NBFC whose borrower data flows to co-lending partners and collection agents, with no way to confirm a withdrawal reached any of them.
Illustrative scenario - not a named customer. Built from how Promiz works, to show the shape of a deployment.
What was the problem?
Borrower data left the NBFC the moment a loan was approved: to a co-lending partner for its share of the book, to a collection agency once an EMI slipped, and to a marketing tool that pushed top-up offers. Consent was a single checkbox on the loan form, so "marketing", "collections" and "underwriting" were one purpose. When a borrower withdrew, the only lever was an email to each partner asking them to stop - and nobody could say when, or whether, they had.
RBI record-keeping made it worse. Loan files must be retained after closure for as long as the applicable rules require, so the operations team was afraid to act on any withdrawal at all: deleting the wrong record was a regulatory breach, keeping the wrong one was a DPDP breach. Section 6(6) asks the fiduciary to stop processing after withdrawal, and Section 6(4) asks that withdrawing be as easy as consenting. Neither could be shown.
What was set up in Promiz?
- 01
Purposes split on the loan form, with OTP-verified consent
Underwriting and RBI record-keeping became legal-obligation purposes. Collections, partner offers and top-up marketing became separate consent purposes, each with its own choice. The borrower confirms with a one-time code, and the shown notice is snapshotted onto the record.
- 02
Signed webhooks to every partner system
Each co-lender, collection agency and marketing tool receives a signed webhook the moment a purpose is withdrawn. The payload names the borrower reference and the purpose, nothing more.
- 03
A stop-processing task per withdrawal
Every withdrawal opens a task with a confirmation deadline. The task closes only when the partner system calls back to confirm it stopped. Anything past its deadline shows as overdue on the obligations queue.
- 04
Legal-obligation purposes stop use, never erase
Withdrawal on a legal-obligation purpose stops marketing use but keeps the loan file. Legal holds freeze any erasure clock for accounts in dispute or under recovery proceedings.
- 05
Receipts for the borrower and the Board
The borrower receives a receipt naming what was withdrawn and when. The same chained record, with the partner confirmations, is what the compliance team exports when asked for proof.
What changed?
- Every partner system now receives the withdrawal and confirms it, and the confirmation is on the record.
- The operations team can see which withdrawals are still open and which partner has not answered, instead of guessing.
- RBI retention and DPDP withdrawal no longer conflict: the loan file stays, the marketing use stops.
- A borrower’s receipt and the compliance export come from the same record, so the two never disagree.
Outcomes are described qualitatively on purpose. Promiz does not publish figures from illustrative scenarios.