Ch IPreliminary
S.1 Short title and commencementS.2 DefinitionsS.3 Application and scopeCh IIObligations of Data Fiduciary
S.4 Grounds for processingS.5 NoticeS.6 ConsentS.7 Certain legitimate usesS.8 Data Fiduciary obligationsS.9 Children’s dataS.10 Significant Data FiduciaryCh IIIRights and duties of Data Principal
S.11 Right to accessS.12 Correction and erasureS.13 Grievance redressalS.14 Right to nominateS.15 Duties of the Data PrincipalCh IVSpecial provisions
S.16 Transfer outside IndiaS.17 ExemptionsCh VData Protection Board of India
S.18 Establishment of the BoardS.19 Composition of the BoardS.20 Salary and term of officeS.21 DisqualificationsS.22 Resignation and vacanciesS.23 Proceedings of the BoardS.24 Officers and employeesS.25 Members as public servantsS.26 Powers of the ChairpersonCh VIBoard powers and procedure
S.27 Powers and functions of the BoardS.28 Procedure followed by the BoardCh VIIAppeal and dispute resolution
S.29 Appeal to the Appellate TribunalS.30 Tribunal orders as a decreeS.31 Alternate dispute resolutionS.32 Voluntary undertakingCh VIIIPenalties
S.33 Penalties and the ScheduleS.34 Penalties to Consolidated FundCh IXMiscellaneous
S.35 Good-faith protectionS.36 Power to call for informationS.37 Blocking of accessS.38 Consistency with other lawsS.39 Bar of jurisdictionS.40 Power to make rulesS.41 Laying of rules before ParliamentS.42 Power to amend the ScheduleS.43 Power to remove difficultiesS.44 Amendments to other ActsB2B SaaS wears two hats: a Fiduciary for your own users and leads, a Processor for the customer data inside your product.
In short
For your own users and marketing you are a Data Fiduciary; for the data customers put in your product you are a Data Processor. Get consent and rights right for the first, and contracts, security and sub-processor control right for the second. Penalties reach ₹250 crore.
What changes for this sub-sector.
Separate the data you decide about (users, leads) from the data you only process for customers.
Sign DPDP-ready processing terms with every customer and every sub-processor.
Website tracking, lead capture and outreach are Fiduciary activities that need consent.
Keep a current sub-processor list, disclose it, and flow duties down by contract.
Handle access, correction and erasure for your own users, and support customers in serving their principals.
Notify affected customers and the Board when a breach touches personal data.
Nail your DPAs and role mapping first, then consent for marketing.
The readiness check maps role, DPA, sub-processor and consent gaps.
Take the readiness check →Consultant-led and partner-backed.