Lesson 8.5: Significant Data Fiduciaries and Rule 13
Large or high-risk fiduciaries carry extra duties. This DPDPA 2023 course page explains significant data fiduciaries and rule 13 in plain language.
What you will learn about significant data fiduciaries and rule 13
- Understand how SDFs are notified
- List SDF duties
- Know the annual DPIA and audit
Section 10 and Rule 13 (significant data fiduciaries and rule 13)
The Government may notify an SDF based on volume and sensitivity of data, risk to principals, potential impact on sovereignty and security, risk to democracy and public order. An SDF must appoint a Data Protection Officer based in India who reports to its Board, appoint an independent data auditor, and carry out a Data Protection Impact Assessment and an audit once every 12 months and report to the Board. It must also verify that algorithmic software does not pose risk, and process specified data only as the Government directs on localisation. Failure can attract a penalty up to Rs 150 crore.
SDF duties: click each
Select a numbered box to read more.
DPIA outline (significant data fiduciaries and rule 13)
| Step | Content |
|---|---|
| Describe | Process, data, purpose |
| Assess | Risks to principals |
| Mitigate | Controls |
| Sign-off | Management and DPO |
Worked example
A large payments platform is notified as an SDF. It appoints a DPO, commissions an annual audit, and files the DPIA summary to its Board.
Activity (5 minutes) (significant data fiduciaries and rule 13)
Read How to do a DPIA and annual audit and complete the DPIA-lite template.
Check your understanding of significant data fiduciaries and rule 13
Q1. SDF DPO must be based in:
Q2. DPIA and audit frequency:
Q3. SDF penalty up to:
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.
