What are the extra obligations of a Significant Data Fiduciary?

Plain-English Statutory Answer
  1. Appoint a Data Protection Officer based in India, responsible to the Board of Directors.
  2. Appoint an independent data auditor to evaluate compliance.
  3. Carry out a periodic Data Protection Impact Assessment (DPIA) and data audit (at least once every 12 months under the Rules).
  4. Follow any additional measures the Rules specify, including due diligence on algorithmic software used to process personal data.

Breach of these obligations can attract a penalty of up to Rs 150 crore.

sdf obligations, extra obligations, additional obligations, dpia, data audit, independent auditor, dpo Updated: Nov 02, 2026
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