Significant Data Fiduciary
Significant Data Fiduciaries (SDFs) face enhanced obligations including mandatory DPO appointment, periodic audits, and Data Protection Impact Assessments.
Who is a Significant Data Fiduciary?
The Central Government notifies Data Fiduciaries as SDFs based on factors including:
Volume of Data
Processing personal data of a significant number of Data Principals
Sensitivity of Data
Processing sensitive personal data at scale
Risk to Rights
Processing that poses significant risk to rights of Data Principals
Impact Assessment
Processing that may have significant impact on sovereignty or security
Technology Used
Use of new technologies with high privacy risks
Additional SDF Obligations
Appoint Data Protection Officer (DPO)
Designate a senior officer as DPO based in India who represents the SDF and is point of contact for Data Principals and the Board.
Appoint Independent Data Auditor
Engage an independent data auditor to evaluate compliance with DPDP Act provisions.
Conduct Data Protection Impact Assessment (DPIA)
Undertake periodic DPIA to assess risks to Data Principal rights from processing activities.
Periodic Compliance Audits
Conduct periodic audits to ensure ongoing compliance with all DPDP Act obligations.
Data Protection Officer Responsibilities
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