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Privacy Glossary

Data Fiduciary

The Indian equivalent of a Data Controller under the DPDP Act — an entity that determines the purposes and means of processing personal data.

DPDP Act

Full Definition

Under India's Digital Personal Data Protection Act 2023, a 'Data Fiduciary' is any person or organisation who, alone or in conjunction with others, determines the purposes and means of processing personal data. The term reflects the fiduciary duty of care owed to the data principal (the individual). Data Fiduciaries must obtain valid consent, provide accessible privacy notices, respond to data principal requests, maintain data accuracy, and implement security safeguards. Certain Data Fiduciaries may be designated as 'Significant Data Fiduciaries' by the central government, attracting additional obligations.

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