Role
A Significant Data Fiduciary is a Data Fiduciary the Central Government notifies as higher-risk under Section 10, carrying extra obligations.
"Significant Data Fiduciary" means any Data Fiduciary or class of Data Fiduciaries as may be notified by the Central Government under section 10.
Not every fiduciary is significant. The government designates SDFs by weighing factors such as the volume and sensitivity of data, risks to individuals, and risks to sovereignty, electoral democracy, security and public order.
Once designated, an SDF must appoint an India-based Data Protection Officer, appoint an independent data auditor, and run periodic Data Protection Impact Assessments and audits (Section 10(2)).
A large platform processing sensitive data on millions of users could be notified as an SDF and would then need a DPO, audits and impact assessments.
See how this term differs from the ones people most often confuse it with.
Data Fiduciary vs Significant Data Fiduciary →Who decides if a fiduciary is significant?
The Central Government, by notification under Section 10, based on the risk factors listed there.
What extra duties does an SDF have?
An India-based DPO, an independent data auditor, and periodic Data Protection Impact Assessments and audits.