DPDP Act FAQs
Can one organisation be a Fiduciary and a Processor at the same time?
Yes, and this is common. The role depends on the activity, not the entity. A logistics firm is a Data Processor when it handles delivery addresses on a retailer's instructions, but a Data Fiduciary for its own employee records and its own direct customers. A marketing agency is a Processor for campaign data it runs on a client's behalf, and a Fiduciary for its own contact database. A manufacturer is a Fiduciary for its dealer network data and a Processor when handling warranty data for a brand it supplies. The practical step is to map roles activity by activity rather than assuming one label describes the whole organisation.
General information on Indian law, not legal advice. For advice on your situation, contact the firm.
Related questions
- What counts as valid consent under the Act?
- What must the notice say before consent is taken?
- Can consent be bundled into general terms and conditions?
- Can I withdraw my consent later?
- What is a Consent Manager?
- Is consent always required, or are there exceptions?
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