Processor
The role of third-party service providers.
🎯 Learning Objectives
- ▸ Define Data Processor
- ▸ Understand the contractual relationship required
The Definition
Section 2(k) defines a Data Processor as any person who processes personal data on behalf of a Data Fiduciary.
Under Section 8(2), a Data Fiduciary can only engage a Processor under a valid contract. The Fiduciary remains responsible for the Processor's compliance.
📖 Glossary
- Data Processor
- An entity that processes personal data on behalf of a Data Fiduciary.
🔑 Key Takeaways
- Processors act on the instructions of the Fiduciary.
- The Fiduciary is liable for the acts of the Processor.
- A valid contract is mandatory between them.
📚 Further Reading
- DPDPA Section 2(k) — Government of India (2023)

Shilpi Kulshrestha
Shilpi is a corporate lawyer with over a decade of experience in data protection, company law, and regulatory compliance. She has advised 50+ startups and enterprises on DPDPA readiness, privacy gover...