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13 of 13|Complete DPDPA Act
video 15 min•Key Definitions
Significant Data Fiduciary
The "big tech" classification with higher obligations.
🎯 Learning Objectives
- ▸ Understand what makes an SDF
- ▸ Learn the enhanced obligations of SDFs
The Criteria
Section 10 allows the government to notify an SDF based on:
- • Volume and sensitivity of data processed.
- • Risk to Data Principals.
- • Potential impact on sovereignty and integrity of India.
- • Risk to electoral democracy.
- • Security of the State.
- • Public order.
Once notified, an SDF must appoint a Data Protection Officer (DPO) who resides in India, appoint an independent data auditor, and conduct Data Protection Impact Assessments (DPIAs).
📖 Glossary
- SDF
- Significant Data Fiduciary, an entity designated by the government with enhanced compliance obligations.
- DPO
- Data Protection Officer, an officer responsible for compliance with the DPDPA.
🔑 Key Takeaways
- SDFs are notified by the government.
- They must appoint a DPO based in India.
- They must undergo periodic data audits.
📚 Further Reading
- DPDPA Section 10 — Government of India (2023)
Course Author
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...