Lesson 2.5: Consent Managers, Significant Data Fiduciaries, the Board and the Tribunal

Module 2 · Lesson 2.5 of 6 · About 30 minutes · Consent Managers Significant Data Fiduciaries

The remaining players and what each does. This DPDPA 2023 course page explains consent managers significant data fiduciaries in plain language.

consent managers significant data fiduciaries - DPDPA 2023 course lesson banner

What you will learn about consent managers significant data fiduciaries

Describe a Consent Manager
Describe a Significant Data Fiduciary
Distinguish the Board from the Appellate Tribunal

Four more actors (consent managers significant data fiduciaries)

A Consent Manager helps a principal give, manage, review and withdraw consent. A Significant Data Fiduciary is notified by the Government. The Data Protection Board adjudicates. The Appellate Tribunal (TDSAT) hears appeals.

Click each actor

Select a numbered box to read more.

Tap or click a step to see exactly what to do.

Who to approach for what (consent managers significant data fiduciaries)

Need	Go to
Complaint against a fiduciary	Fiduciary first, then Board
Appeal against Board order	TDSAT within 60 days
Register as Consent Manager	Board, as per the Rules
Check SDF status	Government notification

Worked example

A person complains to a fintech, gets no reply within the stated time, and then files with the Board. The Board inquires and, if satisfied of a breach, can impose a penalty.

Activity (5 minutes) (consent managers significant data fiduciaries)

Check whether your company might be an SDF. Note factors like data volume and sensitivity.

Key takeaway: Most small firms are not SDFs, but all firms must have a working grievance route.

Check your understanding of consent managers significant data fiduciaries

Q1. Who hears appeals against Board orders?

Q2. A Consent Manager must be:

Q3. Who notifies Significant Data Fiduciaries?

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Educational material for learning purposes, not legal advice. Check the official text of the DPDP Act, 2023, the DPDP Rules, 2025 and MeitY notifications for the latest position.

Official sources for consent managers significant data fiduciaries: Digital Personal Data Protection Rules, 2025 (MeitY, PDF) and DPDP Rules 2025, English text (PDF). Always check the latest official notifications.