The People and Roles Behind the Act

Five terms do almost all the work in the DPDP Act. Once you know who’s who, everything else in this series gets easier to follow.

Role

In plain terms

Notice what’s missing from this list: the Data Processor doesn’t carry direct obligations under the Act the way a Fiduciary does. That’s deliberate the Fiduciary is the one accountable, even for what its processors do on its behalf. Everything about who owes what to whom traces back to this one distinction.
Common misconception — That “Data Fiduciary” isn’t just a fancy word for “Organisations”. It specifically means whoever decides the purpose and means of processing — which can be one team within a larger organisation, not the whole entity.

Learn these five roles once, and the rest of the DPDP Act reads like a set of relationships, not a wall of jargon.

SOURCES  The DPDP Act, 2023 — official text, MeitY — https://www.meity.gov.in/static/uploads/2024/06/2bf1f0e9f04e6fb4f8fef35e82c42aa5.pdf

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