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Additional obligations of a Significant Data Fiduciary

If notified as an SDF: appoint a Data Protection Officer based in India who reports to the board, appoint an independent data auditor, and undertake periodic Data Protection Impact Assessment, periodic audit, and other prescribed measures including algorithmic due diligence.

← S.9S.11 →Open the module
Section 10DPDP Act, 2023Significant Data FiduciaryUp to ₹150 Cr
What this requires

If notified as an SDF: appoint a Data Protection Officer based in India who reports to the board, appoint an independent data auditor, and undertake periodic Data Protection Impact Assessment, periodic audit, and other prescribed measures including algorithmic due diligence.

Up to ₹150 crore for breach of additional obligations of a Significant Data Fiduciary.

Evidence a regulator would accept

  • DPO appointment letter
  • DPIA reports
  • Independent audit report
  • Algorithmic due diligence record

How this product discharges it

dpia (primary)dpoassessment
Our position

Changing this recalculates the readiness score immediately.

Current
Gap
Residual risk
Critical
Owner
Priya Nair
Last reviewed
09 Jun 2026
Next review due
10 Nov 2026

Open gaps (2)

Gaps raised against this obligation. Closing one moves this clause forward.

Evidence (2)

Documents indexed against this obligation in the evidence vault.

History

  1. Clause status updated following remediationyesterday
    06 Aug 2026, 00:30Deepika Joshi
  2. Clause status updated following remediation4 days ago
    03 Aug 2026, 17:30Rohit Verma
  3. Clause status updated following remediation6 days ago
    01 Aug 2026, 10:30Naveen Kulkarni
  4. Clause status updated following remediation8 days ago
    30 Jul 2026, 06:30Vikram Saxena
  5. Clause status updated following remediation10 days ago
    28 Jul 2026, 00:30Imran Sethi
  6. Clause status updated following remediation13 days ago
    25 Jul 2026, 16:30System
  7. Position reviewed and recorded2 months ago
    09 Jun 2026, 11:55Priya Nair

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