DPDP Glossary
Significant Data Fiduciary
A Data Fiduciary or class of Data Fiduciaries notified as such by the Central Government, with additional obligations under Section 10 and Rule 13.
Section 10; Rule 13
What it means
A Significant Data Fiduciary is a Data Fiduciary or class notified as such by the Central Government. Section 10 and Rule 13 impose additional obligations on notified SDFs. Designation is by notification — organisations do not self-appoint as SDFs, and absence of notification is not a guarantee designation will never come.
Worked example
A mid-size SaaS company should not claim “we are an SDF” in marketing without a government notification that says so. Conversely, ignoring volume, sensitivity and risk factors the government may use for designation leaves you unprepared if a class notification lands.
In practice
Monitor notifications. If designated, map Section 10 / Rule 13 extras (including any DPO and audit expectations the law attaches) as a programme overlay on top of ordinary Fiduciary duties — not a replacement for Section 8.
Source
Section 10; Rule 13 · Official text (PDF)
Educational summary based on the Digital Personal Data Protection Act, 2023 and Rules, 2025. Not legal advice.