The Tripartite Classification
DPDPA's entity classification creates a three tier hierarchy with ascending accountability.
At the base, Data Processors process personal data on behalf of Data Fiduciaries under contractual instruction. They bear limited direct statutory obligations but remain subject to contractual accountability requirements.
Standard Data Fiduciaries are entities that determine the purpose and means of processing. They bear the full weight of DPDPA obligations including consent management, rights fulfilment, security safeguards, and breach notification.
At the apex, Significant Data Fiduciaries face enhanced obligations reflecting their elevated risk profile. This tiered approach recognises that data protection risks do not correlate perfectly with entity size or processing volume. It enables calibrated regulatory intervention that avoids both under regulation of high risk processors and over regulation of low risk entities.
