Readiness assessment

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Data Fiduciary vs Significant Data Fiduciary

Every Significant Data Fiduciary is first a Data Fiduciary. The 'significant' label is added by the Central Government for higher-risk fiduciaries, and it brings extra obligations.

Data Fiduciary
Significant Data Fiduciary
Who it is
Any person deciding the purpose and means of processing.
A fiduciary notified as higher-risk under Section 10.
Statutory reference
Section 2(i)
Section 2(z) / Section 10
How the role arises
By determining purpose and means.
By Central Government notification, on risk factors.
Data Protection Officer
Not mandatory.
Mandatory, India-based (Section 10(2)(a)).
Independent data auditor
Not required.
Required (Section 10(2)(b)).
Impact assessment and audit
Not required.
Periodic DPIA and audit required (Section 10(2)(c)).

Related glossary terms

Frequently asked questions

What makes a fiduciary 'significant'?

A Central Government notification under Section 10, based on data volume and sensitivity and risks to rights, sovereignty, security and public order.

What extra duties apply?

An India-based DPO, an independent data auditor, and periodic impact assessments and audits.