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Data Fiduciary vs Data Processor

The difference comes down to control. A Data Fiduciary decides why and how personal data is processed. A Data Processor only acts on the fiduciary's instructions. The fiduciary carries the responsibility either way.

Data Fiduciary
Data Processor
Plain definition
Decides why and how personal data is processed.
Processes personal data on behalf of a Data Fiduciary.
Decides purpose and means?
Yes. This is what defines the role.
No. It follows the fiduciary's instructions.
Statutory reference
Section 2(i)
Section 2(k)
Acts for
Itself, and its own stated purposes.
The Data Fiduciary that engaged it.
Primary responsibility
Non-delegable under Section 8(1).
Acts under contract; fiduciary stays accountable.
Needs a contract?
Engages processors under a valid contract (Section 8(2)).
Must be engaged under a valid contract.
Everyday example
A bank collecting KYC to open accounts.
A vendor the bank hires to verify the KYC.

Related glossary terms

Data FiduciaryData ProcessorSignificant Data FiduciaryProcessing

Frequently asked questions

Can one company be both?

Yes. It is a fiduciary for its own purposes and a processor when handling another fiduciary's data under instruction.

Who is liable if a processor mishandles data?

The fiduciary carries primary responsibility and stays accountable for the processor's compliance.

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