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Page A-023

Data Processors vs Data Fiduciaries: Operational Responsibilities Explained

https://trust.digitalanumati.com/data-processors-vs-data-fiduciaries-operational-responsibilities/

3.7%

of A-023 overlaps A-082

Page A-082

Vendor Due Diligence for BFSI Data Processors under DPDP and

https://trust.digitalanumati.com/vendor-due-diligence-bfsi-data-processors/

0.0%

of A-082 overlaps A-023

Matching passages

Paragraph match score 79.9%

Page A-023

Data Processors vs Data Fiduciaries: Operational Responsibilities Explained

Under the DPDP Act, the data fiduciary decides why and how personal data is processed and holds primary regulatory accountability; the data processor acts on that instruction but still has meaningful operational and contractual duties.

Page A-082

Clarifying key questions about BFSI data-processor governance

In DPDP terms, your bank, NBFC, insurer, or fintech is typically the data fiduciary because it decides why and how customer data is processed, and it carries the primary compliance obligations and liability. Vendors that process data only on your documented instructions—such as SaaS providers, cloud platforms, KYC utilities, or call centres—are data processors, and must follow your instructions and implement suitable safeguards. Your due diligence should therefore focus on whether each processor can technically and operationally support your obligations as the fiduciary.