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Consent
Architecture

Machine-readable consent records and receipts as defined by ISO/IEC TS 27560:2023, implemented using the W3C Data Privacy Vocabulary (DPV). Build consent systems that are interoperable, auditable, and compliant with GDPR, DPDP, and global privacy regulations.

Consent Records vs. Consent Receipts

The W3C Data Privacy Vocabulary (DPV) — developed by the Data Privacy Vocabularies and Controls Community Group (DPVCG) and now at version 2.3 — defines the core concepts for representing consent in machine-readable form. The DPV framework distinguishes between two related but distinct concepts:

Consent Record

The internal documentation of a data subject's consent for processing of their personal data. Includes metadata, processing details, involved parties, and event provenance. Required for demonstrating compliance under regulations like GDPR Article 7.

Consent Receipt

An authoritative copy of a consent record provided to another entity — typically the data subject. Analogous to a shopping receipt. Enables data subjects to track what they consented to and exercise their rights.

ISO/IEC TS 27560:2023 is the international standard that specifies an interoperable, open, and extensible information structure for consent records and receipts. The DPV profile for 27560 (dpv-27560) provides a complete implementation schema using DPV concepts. This approach is jurisdiction-agnostic — the same information structure works across GDPR, India's DPDP Act, Brazil's LGPD, and Canada's PIPEDA.

ISO 27560 Consent Record Structure

A consent record under ISO/IEC TS 27560:2023 contains four sections. Fields in bold are mandatory.

1 Metadata — Header Fields

Schema Version (mandatory)
e.g. dpv-27560:record
Record Identifier (mandatory)
Unique ID for the consent record
Data Subject (mandatory)
The individual who gave consent
Creation Timestamp (mandatory)
When the record was created

2 Processing Information

Purpose(s) (mandatory)
Why the data is processed
Personal Data (mandatory)
Categories and identifiers of data
Data Controller (mandatory)
Who controls processing
Legal Basis (optional)
e.g. Consent, Legitimate Interest
Processing Operations (optional)
Collect, store, share, analyze
Storage & Retention (mandatory)
Location, duration, deletion policy
Recipients (mandatory)
Third parties who receive data
Jurisdiction (mandatory)
Applicable law and regulatory body

3 Parties — Entity Information

Party Identifier (mandatory)
Legal entity ID (DID, LEI, VAT)
Party Name (mandatory)
Registered legal name
Party Address (mandatory)
Registered address
Contact (optional)
Email, phone, URL
Role (optional)
Controller, Processor, Third Party

4 Consent Event Fields

Consent Type (mandatory)
Expressed, Explicit, Implied
Consent State (mandatory)
Given, Withdrawn, Expired
Event Time (mandatory)
When consent was expressed
Duration (mandatory)
Validity period of consent
Expression Method (optional)
Click, checkbox, biometric, signature
Withdrawal Method (mandatory)
How consent can be withdrawn

Consent Lifecycle in DPV

DPV defines a structured lifecycle for consent states, enabling systems to track and verify consent validity over time. The lifecycle below follows the model from the DPV-27560 guide:

Notice
Shown

Information is provided to the data subject via a consent notice. DPV relation: dpv:hasNotice with dpv:ConsentNotice.

Consent
Requested

Consent is solicited from the data subject. DPV status: dpv:ConsentRequested.

Consent
Given

Data subject grants consent. DPV status: dpv:ConsentGiven. A consent record is created. A receipt may be issued to the data subject. Processing may begin.

Consent
Re-confirmed

Consent validity is re-affirmed. The status remains dpv:ConsentGiven but the record is updated with a new confirmation event and timestamp.

Consent
Terminated

Consent ends for any of: withdrawal (dpv:ConsentWithdrawn), expiry, termination by controller, or invalidation by authority. Processing must stop.

Source: DPV Consent Lifecycle as defined in the DPV-27560 Consent Records and Receipts Guide.

DPV Model for Consent

The DPV provides the following core concepts and relations for modelling consent. These are the building blocks for implementing the ISO 27560 information structure.

DPV Concept Type Description
dpv:Consent Legal Basis Consent as a legal basis for processing. Extended by ExpressedConsent, ExplicitlyExpressedConsent.
dpv:ConsentStatus Status Current stage of consent. Includes ConsentRequested, ConsentGiven, ConsentWithdrawn.
dpv:ConsentRecord Measure Documentation of consent information per ISO 27560. An organisational measure for accountability.
dpv:ConsentReceipt Measure Authoritative copy of a consent record provided to another entity.
dpv:ConsentNotice Notice The notice shown to the data subject when requesting consent.

Key Relations

dpv:hasLegalBasis

Associates processing with consent as its legal basis.

dpv:hasConsentStatus

Indicates the current status of consent.

dpv:hasIndicationMethod

How consent was expressed (click, biometric, signature).

dpv:isIndicationTime

Timestamp when consent was given or withdrawn.

dpv:hasDataSubject

Identifies the individual who gave consent.

dpv:hasConsentControl

Mechanism for withdrawal (e.g., WithdrawConsent).

DPV Profiles for ISO 27560

The DPVCG defines four standard profiles for implementing ISO/IEC TS 27560:2023, each under the dpv-27560 namespace:

dpv-27560:record

Consent Records conforming to ISO 27560. Contains all mandatory fields: schema version, record identifier, data subject, purpose, personal data, controller, storage, recipients, jurisdiction, consent type, state, event time, duration, withdrawal method.

dpv-27560:record-eu-gdpr

Extends the base record with GDPR-specific requirements including: lawful basis, processing operations, data source, automated decision-making, retention period, and supervisory authority information.

dpv-27560:receipt-record

Consent Receipt providing a copy of the consent record. Includes receipt identifier, associated consent record reference, schema version, and creation timestamp plus any subset of record fields.

dpv-27560:receipt-eu-gdpr

GDPR-specific consent receipt that includes all information required by GDPR Articles 13 and 14 to be provided to the data subject.

Regulatory Alignment via DPV Extensions

DPV achieves jurisdiction-specific compliance through extensions. Each law or regulation has a dedicated namespace that extends the core DPV model with jurisdiction-specific concepts.

EU GDPR

Extension: legal/eu/gdpr

Concepts for consent under GDPR Article 4(11), Article 7, and Recital 42. Includes explicit consent, withdrawal, records of consent, and supervisory authority interactions.

India DPDP Act 2023

Extension: legal/in/dpdp (proposed, v2.4)

Concepts for India's Digital Personal Data Protection Act: consent managers, data fiduciaries, significant data fiduciaries, legitimate uses, children's data, and grievance redressal. See DPV Issue #438.

Brazil LGPD

Extension: legal/br

Lei Geral de Proteção de Dados — consent, legitimate interest, data subject rights, and ANPD (authority) concepts. Mapped via DPV legal extensions framework.

Canada PIPEDA

Extension: legal/ca

Personal Information Protection and Electronic Documents Act — meaningful consent, purpose specification, and accountability principles aligned with DPV core concepts.

Building a Consent Management System

A production consent management system built on DPV and ISO 27560 should address the following architectural layers:

1

Consent Record Store

Persistent storage for consent records with schema validation against the dpv-27560 profile. Each record tracks the full lifecycle — initial grant, updates, re-confirmations, and withdrawal. Records are immutable append-only logs with cryptographic integrity.

2

Notice Management

Versioned consent notices with language support. Each notice is referenced by the consent record via dpv:hasNotice. Changes to notices are tracked so consent validity can be evaluated against the notice that was shown at the time of consent.

3

Consent Lifecycle Engine

State machine managing transitions: requested → given/refused → given/re-confirmed → withdrawn/expired/invalidated. Each transition generates a consent event recorded in the store.

4

Receipt & Signal Distribution

Consent receipts are issued to data subjects. Shared Signals events (via OpenID SSF) propagate consent changes — withdrawal, expiry, scope updates — to all data consumers in the ecosystem in real time.

Further Reading