Who is a Data Fiduciary?

A Data Fiduciary is any person who, alone or with others, determines the purpose and means of processing personal data. The word fiduciary is deliberate: it signals a relationship of trust rather than mere possession. A hospital deciding how patient records are used, an employer deciding how staff data is handled, a retailer deciding what customer data to collect, and a law firm deciding how client information is stored are all Data Fiduciaries. The obligations under the Act rest primarily on them.