Cloud and infra providers are Processors for almost everything customers run on them, plus Fiduciary for their own account data.
In short
Cloud and infrastructure providers are Processors for customer workloads and Fiduciaries for their own account and billing data. Localization, security and sub-processor transparency dominate the obligations. Penalties reach ₹250 crore.
What changes for this sub-sector.
You process whatever customers store and run; act on documented instructions under contract.
Offer and honour data-residency choices; some sectors and rules require India-based storage.
Make the shared-responsibility split explicit so no security duty falls between the cracks.
Disclose region operators and downstream providers you rely on.
Where data crosses borders, ensure it is permitted and contractually covered.
Give customers breach-notification timelines they can meet their own DPDP duties with.
Clarify residency and the shared-responsibility model first.
The readiness check flags residency, shared-responsibility and sub-processor gaps.
Take the readiness check →