DPDP enforcement deadline: May 2027Rules notified Nov 2025Penalty exposure up to ₹250 Cr
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Quick Answer

Under DPDP Act 2023, a Data Fiduciary determines the purpose and means of processing. A Data Processor processes data on behalf of the Fiduciary under instructions. Most organisations are Fiduciaries for some data and Processors for other data. Your role determines your obligations — Fiduciaries bear the primary compliance burden.

Data Processor vs Fiduciary Checker

Determine your DPDP Act role — Fiduciary or Processor — and understand your specific compliance obligations.

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Frequently Asked Questions

Can an organisation be both a Data Fiduciary and a Data Processor?+
Yes, this is very common. A B2B SaaS company is a Fiduciary for its own user accounts and a Processor for client data uploaded to the platform. Different DPDP obligations apply to each role, and both must be addressed in the compliance programme.
What are the obligations of a Data Processor under DPDP?+
Data Processors must: implement security safeguards, notify the Data Fiduciary of breaches within 24 hours, process data only as instructed, not engage sub-processors without fiduciary consent, and delete data at contract end. Section 8 of the DPDP Act covers Processor obligations.
What is a Significant Data Fiduciary?+
A Significant Data Fiduciary (SDF) is a category of Data Fiduciary designated by the Central Government based on risk. SDFs face enhanced obligations including mandatory DPIA, algorithmic audits, and a Data Protection Officer appointment.

Related DPDP Tools

Fiduciary Obligations CheckerProcessor Obligations GuideSaaS DPDP PackLegal Team Checker
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