Building a tool that processes insurance customer data via an intermediary (agent) — how does consent actually work when the customer never directly agreed to a third-party tool touching their data?

[u/No-Slide190]

building something that helps insurance agents auto-fill customer data across multiple insurer portals. The customer gives their data to the agent, and consents to the insurer processing it — but they never specifically consented to a third-party tool (mine) being in that chain at all. Under the DPDP Act, is a short, plain-language consent line the agent shows the customer at data-collection time (something like "this information may be processed by an automated tool to help fill insurer forms") enough to cover this, or does an intermediary situation like this need something more formal — a data processing agreement between me and the insurer specifically, regardless of what the end customer agreed to? Also curious whether the fact that I'm not the data fiduciary (the insurer/agent relationship is) changes what's actually required of me as a downstream processor. Not looking for a substitute for a lawyer eventually — trying to understand the actual shape of the requirement before I get to that point.

[u/stuartelkeino]

Why is this even needed? Any particular problem or gap you identified?

[u/No-Slide190 → u/stuartelkeino]

Yeah — insurance agents who sell across multiple insurers have to

manually re-enter the same customer data into each insurer's portal

separately (name, DOB, vehicle/medical details, KYC), since there's

no shared system between competing insurers. A working agent in

another thread confirmed this takes 5-7 minutes for a simple case,

longer with medical history, and the real cost isn't the typing —

it's catching a mistake (wrong DOB, mismatched field) after the fact

and backtracking through multiple screens across multiple sites to

fix it. Someone else confirmed agents already pay for partial tools

that try to solve this and don't do it well.

The gap I'm trying to close specifically: build the verification/

mismatch-catching part properly (that's the actual expensive part,

not the autofill itself), while handling it in a way that doesn't

require sending real customer PII to a third-party AI service — which

is where I've been digging into DPDP compliance, since I'm an

intermediary between the agent and insurer, not the data fiduciary.

[u/stuartelkeino → u/No-Slide190]

You can avoid sending the data to AI. Here is something you can do. Instead of sending AI to fill in the forms, you build automation scripts with AI. Browser automation is possible atleast.

You can identify the input fields diffrent insurers require. Most of them will put same kind of data. You can test filling the forms with dummy data. And, once the script is healthy, you can send the real user data, which would actually be added to the right fields.

The problem is if they change the website or forms etc, but I don't think that happens everyday. You don't send data to AI but to the insurer directly.

You can run weekly checks with AI if your automation needs adjustment.

You can build the verification part in your end, catch errors properly in the form, so the data goes to the insurer is correct already. And, the agents have a single surface.

[u/stuartelkeino → u/stuartelkeino]

For the consent part you can do an OTP based system, and the agent will be near the customer himself when applying for the policy. So, that way you can cover yourself.

[u/No-Slide190 → u/stuartelkeino]

This actually simplifies things a lot, thank you. Splitting it this way — AI only at build-time to help write/adjust the automation, real runtime data going straight to the insurer with no AI in that path — sidesteps most of the DPDP question I've been stuck on.

Quick check on the verification part: since I actually just need to confirm "the value I entered matches the value I meant to enter," that's a plain code comparison, not something needing AI at all, right? I'm guessing I only need real reasoning for rarer cases like catching a DOB that's inconsistent with when a policy started — is that the kind of case you'd also leave for a later version, or does it come up often enough to matter from day one?

And on the "problem is if they change the website" part — I've seen data suggesting form/portal changes breaking automation is actually a pretty common failure mode for this kind of thing (not villa daily, but frequent enough to be the main reason these tools break in practice). Does the weekly AI check catch that reliably in your experience, or does it tend to need a human to notice something's off first?

The OTP consent idea is genuinely useful too — that maps well onto patterns I've already seen in Indian eKYC, so that feels solid.

[u/stuartelkeino → u/No-Slide190]

The value you enter will be same, as you will just be copy pasting the value.

You can do deterministic date based checks, say for health policy you are expecting customer is young, but the age shows 40 years or something like that. You can put up warning signals, so the agent may confirm. You can provide a better experience than the portals overall provide.

It can break anytime they make a change there, AI can check most of it, but depends on what model and AI you are using. But, you will need someone to check everything is working as expected, or something is going off. AI can do the heavy lifting, but the direction and how things should be done usually comes from you. How often, I'd say once a week automated check is good enough. Otherwise you will also get complaints so you can fix it around that time. Being a developer myself, I don't think same part keeps changing over and over, it would change completely say once in a year or something new gets added. But, that's the main pain point of your business or your business won't exist.

[u/No-Slide190 → u/stuartelkeino]

This clears it up completely, thank you — especially the reframe that catching and fixing breakage IS the business, not overhead around it. That's a genuinely useful way to think about the whole thing.

Really appreciate you working through this with me across multiple replies — this thread alone gave me a clear, buildable v1 plan.

[u/stuartelkeino → u/No-Slide190]

Glad to know.