SaaS companies wear two hats under the Act; getting the roles, contracts and sub-processors right is the whole game.
In short
SaaS companies wear two hats: a Data Fiduciary for your own users, and a Data Processor for customer data. You need clear consent and rights for your users, and airtight contracts, security and sub-processor control for customer data. Penalties reach ₹250 crore.
The obligations that shape compliance in this sector.
Know which role you play for which data; the duties are different for each.
Put valid processing contracts in place with customers and every sub-processor.
Reasonable security is a legal duty; access control, encryption and logging are table stakes.
For your own users, handle consent, access, correction and erasure directly.
Disclose and control the vendors that process data on your behalf.
Notify affected customers and the Board when a breach touches personal data.
Each sub-sector has its own data flows and its own version of the rules.
Wherever you are, start there and move through to a certifiable posture.
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