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You filled out a loan comparison form on a popular aggregator website — BankBazaar, PaisaBazaar, or a similar platform. You entered your income, PAN, phone number, and employment details. You selected three lenders to "check eligibility."
Within an hour, your phone had received calls from 11 different lenders, including ones you had never selected. By the end of the week, your CIBIL showed 9 hard inquiries — your score had dropped 45 points.
You did not consent to 9 hard inquiries. You did not consent to your data being shared with 11 lenders. But somewhere in the aggregator's terms — which you clicked "Agree" to without reading — was a broad consent clause that permitted all of this.
Under the DPDP Act 2023, this is no longer unambiguously legal.
How Loan Aggregators Make Money
Loan aggregators earn through two primary mechanisms:
Referral fees: When you are approved for a loan through a lender referred by the aggregator, the aggregator earns a commission — typically 0.5–2% of the loan amount. A ₹5 lakh loan might generate ₹5,000–₹10,000 for the aggregator.
Data monetisation: Aggregators collect rich financial profiles — income, employment, existing debts, loan purpose. This data has value beyond the immediate referral. Some aggregators share it with insurance companies, investment platforms, and other financial services.
The business model has an inherent conflict: the aggregator earns more when more lenders receive and process your data. Your interests — minimal data sharing, minimal credit inquiries — are opposite to their revenue interests.
What the DPDP Act Changes
Under the Digital Personal Data Protection Act 2023:
Consent must be specific: A blanket consent to "share data with all our lending partners" may not constitute valid consent for each individual lender. Consent should specify which lenders, for what purpose.
Data minimisation: Aggregators should collect only the data necessary for the service. If you are comparing 3 lenders, your data should not be sent to 11.
Right to withdraw: Even if you gave initial consent, you can withdraw it going forward.
Purpose limitation: Data collected for loan comparison cannot be used for unrelated purposes (insurance marketing, investment platforms) without separate consent.
Your Practical Rights After Using an Aggregator
Step 1: Know what inquiries have been made
Pull your CIBIL report (free annually at cibil.com) and check the "Enquiry Information" section. Every hard inquiry shows which lender made it and when. If you see lenders you never authorised, note their names.
Step 2: Contact lenders making unauthorised inquiries
For each unauthorised inquiry, contact the lender: "I did not authorise [Lender Name] to make an inquiry on my CIBIL. Please provide the consent documentation that authorised this inquiry. If you cannot, I request that this inquiry be removed from my CIBIL file."
Lenders who cannot demonstrate valid consent for the inquiry have an obligation to request its removal from CIBIL.
Step 3: Contact the aggregator for data deletion
"Under the DPDP Act 2023, I request confirmation of what personal data you hold about me and request deletion of all data beyond what is necessary for your service, particularly regarding sharing with lenders beyond those I explicitly selected."
Step 4: File a DPDP complaint for egregious cases
If you experienced significant harm (major score drop from multiple unauthorised inquiries, harassessment from multiple unexpected lenders), document and prepare to file with the Data Protection Board when it becomes fully operational.
Protecting Yourself for Future Loan Comparison
Use SahiSujhav's Loan App Reviews: Compare lenders on APR and transparency without making any applications or triggering any inquiries.
Apply directly, not through aggregators: Once you have identified your preferred lender(s) through comparison, apply directly on the lender's website or app — your data goes to that lender only.
If you must use aggregators: Read the consent section carefully. Look for opt-out options for data sharing beyond specific selected lenders. Screenshot the consent page before proceeding.
SahiSujhav's loan comparison never triggers inquiries — compare without risk at www.sahisujhav.com
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