What extra obligations apply to a Significant Data Fiduciary (SDF)?

Reviewed by: Santosh Raut
Senior IT Architect & Privacy Technology Consultant
Last Updated: 05 June 2026

Answer:

Significant Data Fiduciaries - notified by the Government based on volume and sensitivity of data, risk to data principals and to sovereignty, security and public order - must appoint a Data Protection Officer based in India, conduct an annual Data Protection Impact Assessment and independent audit, undertake due diligence to verify that algorithmic software does not pose risks to data principals, and observe any restrictions on transferring specified personal data outside India.
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