Data Fiduciary Advisory
Legal guidance on data fiduciary and data processor obligations, consent frameworks, and privacy notice drafting under DPDP Act.
Overview
Under the DPDP Act 2023, a Data Fiduciary is any entity that determines the purpose and means of processing personal data, and this role carries significant legal obligations including consent management, grievance redressal, and data localisation in certain cases. We advise organisations on their classification as Data Fiduciaries or Significant Data Fiduciaries, the specific obligations that apply to each category, and practical steps to meet these requirements. Our advisory covers appointment of a Data Protection Officer where mandated, implementation of data principal rights mechanisms, and preparation for audits by the Data Protection Board. Understanding and fulfilling Data Fiduciary obligations is critical to avoiding penalties under the DPDP Act.
Documents Required
List of personal data collected and processed
Existing privacy notices and consent forms
Data processing agreements with third parties
Organisation structure and data governance policy
Current data retention and deletion policies
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