Readiness assessment

Role

Data Processor

A Data Processor processes personal data on behalf of a Data Fiduciary, under that fiduciary's instructions and a valid contract.

Defined inSection 2(k)
CategoryPeople & Roles
Applies toVendors processing data on a fiduciary's behalf

What the Act says

DPDP Act 2023, Section 2(k)

"Data Processor" means any person who processes personal data on behalf of a Data Fiduciary.

In plain language

The Data Processor acts for the fiduciary, not for itself. It handles data to deliver a service, but does not decide the purpose or means.

A fiduciary may engage a processor only under a valid contract (Section 8(2)), and stays responsible for the processor's compliance. The duty cannot be contracted away.

Example

A payroll company that processes employee data strictly as its client instructs is a Data Processor. The employer is the Data Fiduciary.

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See how this term differs from the ones people most often confuse it with.

Data Fiduciary vs Data Processor →

Related terms

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Frequently asked questions

Is a Data Processor liable under the Act?

The fiduciary carries primary responsibility. A processor acts under contract and instructions, and the fiduciary stays accountable.

Can one company be both?

Yes. It can be a fiduciary for its own purposes and a processor when handling another fiduciary's data.

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