NDPA modules · Consent
She said stop. Three systems heard it.
A consent register that records the withdrawal correctly and changes nothing downstream is not a compliance record. It is a receipt for a promise you did not keep.
- Consents held
- 40,100
- Withdrawals not delivered
- 1
- Consents only on paper
- 1,890
- Halima Sani withdrew consent on 22 Jun 2026 · 09:14: Unticked marketing emails in the app. The consent register recorded it correctly.
- Marketing email (Intuit Mailchimp): Still in the audience. Two campaigns sent since. Withdrawal stuck 36 days.
- Core banking (Oracle Flexcube): Preference flag cleared at 09:14.
- Support (Zendesk): Agent view updated at 09:14.
- Event stream (Twilio Segment): Marketing events stopped at 09:15.
The register is right and the outcome is wrong, because nothing carried the withdrawal outward and nothing raised an error. Two campaigns have gone out since.
What a consent record has to carry
A tick in a box proves that somebody ticked a box
It does not prove what they were told, when, or that saying no was genuinely available. Under the Act, the burden of proof is yours — so the record has to answer questions asked years later by somebody hostile.
What most systems store
marketing_opt_in = true
- ✓
That the flag is currently true or false
- ✕
The exact wording they were shown
- ✕
Which version of the notice was live that day
- ✕
Whether refusing was actually possible
- ✕
The withdrawal, and when it was honoured
- ✕
Which systems were told, and which were not
What Asiri keeps
CON-0117 · v3 wording
- ✓
The wording shown, stored as shown
- ✓
Notice v3, published 22 Jun 2025, linked
- ✓
Given 4 Mar 2023 · 14:07 · in the app
- ✓
Withdrawn 22 Jun 2026 · 09:14 · in the app
- ✓
Three systems honoured it, one did not
- ✓
Every read of this record, and by whom
Junior savings · parental consent
One thousand eight hundred and ninety, in a filing cabinet in Ikeja
Every one of them was properly given. A parent came into a branch, was verified, signed a form. The product is lawful and the consent is real — and none of it can be produced for the NDPC inside the seven days a request allows.
Asiri counts these as held-on-paper rather than as held, because the distinction is the whole of your exposure. A consent you cannot show is a consent you cannot rely on.
1,890
Four things consent has to be
If saying no changes nothing, it was never consent
Asiri checks the shape of the ask, not only the answer. A pre-ticked box, a bundled agreement, or a withdrawal buried three screens deep all produce a record that looks clean and would not survive being read out.
Freely given
Refusing has to be a real option. If the service stops working when somebody says no, you needed a different lawful basis — not a better consent screen.
Specific and unbundled
One purpose, one ask. A single tick covering marketing, analytics and partner sharing is three consents wearing one coat.
Informed, in words they read
The wording is part of the record. If the notice changes materially, the old consent covers the old wording only.
As easy to take back as to give
One click in, one click out. And the withdrawal has to reach the system that acts on it — which is where almost everyone fails.
Pick one person who withdrew and follow it outward
Asiri reads your marketing audiences hourly and compares them against the consent register. If somebody who said stop is still on a list, you hear it from us rather than from them.