A Significant Data Fiduciary (SDF) is a Data Fiduciary notified by the Central Government based on factors including volume and sensitivity of personal data processed, risk to data principal rights, potential impact on sovereignty and security, and risk to electoral democracy. SDFs have additional obligations under Section 10 of the DPDP Act: appointment of a Data Protection Officer (DPO) based in India, appointment of an independent Data Auditor, periodic Data Protection Impact Assessments (DPIA), and compliance with additional prescribed requirements. Most large banks, public sector entities, social media platforms, and e-commerce companies are expected to be classified as SDFs.
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For specific advice on how Significant Data Fiduciary applies to your debt recovery matter, consult Advocate Subodh Bajpai — LLM, MBA (XLRI Jamshedpur). 8+ years of exclusive banking and debt recovery practice across DRT, SARFAESI, IBC, and NI Act.
Defined by Advocate Subodh Bajpai, Senior Partner, Unified Chambers and Associates