Home / Who is covered
Free quiz · 8 questions

Am I a Data Fiduciary?

The Act does not have a size threshold, but it does have four distinct roles. Whether you're a Data Fiduciary, a Data Processor, a Consent Manager, or a Significant Data Fiduciary changes what you have to do. Answer eight yes-or-no questions and this page tells you which role you're in and what to do next. Runs in your browser, so nothing about your business goes anywhere.

Client-side compute DPDP Act Sections 2, 3, 10 60 seconds
Question 01 of 8

Do you process any personal data of individuals located in India?

Personal data means any data that identifies an individual or from which an individual can be identified. (Sec. 2(t), Sec. 3)

Question 02 of 8

Is that personal data in digital form (or digitised after collection)?

DPDP applies only to digital personal data. Paper-only records are outside. (Sec. 2(n), Sec. 3)

Question 03 of 8

Do you (alone or with others) decide the purpose and the means of processing?

If yes, you are a Data Fiduciary. If someone else decides and you only execute, you may be a Data Processor. (Sec. 2(i))

Question 04 of 8

Is the processing for personal or purely domestic use?

Individual use (personal contacts, family photos) is outside DPDP. (Sec. 3(c))

Question 05 of 8

Do you process personal data of more than 5 million Indians?

A rough SDF-candidacy signal. Volume is one of the six Sec. 10(1) factors. (Sec. 10(1))

Question 06 of 8

Do you process financial, health, biometric, children's or government-ID data at meaningful scale?

Sensitivity is another SDF-candidacy signal. (Sec. 10(1))

Question 07 of 8

If you are outside India, do you offer goods or services to individuals in India?

Section 3(b) applies extra-territorially to foreign entities serving India. (Sec. 3(b))

Question 08 of 8

Have you received a written notice from the Central Government designating you a Significant Data Fiduciary?

This is a Yes / No fact. Do not guess. (Sec. 10)

Why

What to do next

Not legal advice. This quiz is a decision-support tool. Confirm your classification with counsel before taking public positions.