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Data fiduciary

The person determining the purpose and means of processing personal data under the DPDP terminology.

Search terms: DF data controller

A business example

A retailer decides to collect customer contact details for deliveries and instructs a software provider to store them.

How the roles connectFictional business scenario
  1. Purpose decision

    The retailer decides why the information is collected.

  2. Processing design

    The retailer determines relevant means and instructs its provider.

  3. Vendor role

    The provider performs the agreed processing on the retailer's behalf.

What this shows

Using hosted software does not automatically move the retailer's decision-making role to the vendor. Assess each activity and relationship.

What it is often confused with

Using a vendor does not necessarily transfer the retailer's own role or responsibility.

What to look at in your business

Record who determines each processing purpose and how vendors are instructed.

Context and further reading

MeitY: Digital Personal Data Protection Act, 2023. This reference supports the terminology; use the linked guide for applicability and operative requirements.

DPDP implementation phases →

Related terms

Personal data

Information relating to an individual who is identifiable by or in relation to that information.

Data principal

The individual to whom personal data relates under the DPDP terminology, with specified representation rules in some cases.

Data processor

A person processing personal data on behalf of a data fiduciary under the DPDP terminology.