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2 of 8|Significant Data Fiduciary (SDF)
reading 20 min•SDF Framework
Eligibility Criteria
Why does a company get classified as an SDF?
🎯 Learning Objectives
- ▸ Analyze the factors for SDF classification
- ▸ Understand the risk-based approach
The Criteria
Section 10(1) lists the factors the government will consider before notifying an SDF:
- • The volume and sensitivity of personal data processed by the Data Fiduciary.
- • The risk to the rights of the Data Principal.
- • The potential impact on the sovereignty and integrity of India.
- • The risk to the security of the State.
- • The risk to public order.
- • The risk to electoral democracy.
💡 Example
A social media platform with 500 million Indian users collects massive amounts of behavioral data. Because it can influence elections (risk to electoral democracy) and public order, it is highly likely to be classified as an SDF.
📖 Glossary
- Electoral Democracy
- A democratic system where political power is exercised through free and fair elections, which can be vulnerable to data manipulation.
🔑 Key Takeaways
- Volume of data is a major factor.
- Sensitivity of data (like health or financial data) is critical.
- Risk to electoral democracy and national security are also considered.
📚 Further Reading
- DPDPA Section 10(1) — 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...