Concept
Data Processor
An organisation that processes personal data on behalf of a Data Fiduciary. Duties reach it mainly through its contract with the fiduciary: section 8(2) allows a fiduciary to engage a processor only under a valid contract. Section 8(2) commences on 13 May 2027, a date computed from the notification, so treat it as interpretation until officially confirmed.
“Data Processor” means any person who processes personal data on behalf of a Data Fiduciary
Read section 2 of the Act, where this term is defined →
Related tool
Role and Actor Checker
Work out your likely role for a processing activity, such as Data Fiduciary or Data Processor.
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Related tool
Vendor and Processor Checklist
Identify DPDP relevant actions for your vendors and Data Processors.
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Data Fiduciary vs Data Processor: which role are you? →Do you need a contract with your Data Processor under DPDP? →
Sources cited on this page
- [1]The Digital Personal Data Protection Act, 2023 (Gazette print hosted by MeitY) (Act No. 22 of 2023), s. 2(k), p. 2. Published 11 August 2023. Official source ↗ · Official requirement · Verified 17 August 2026In force since 13 November 2025