Glossary
Data Fiduciary and Data Processor
Under the DPDP Act, the Data Fiduciary decides the purpose and means of processing personal data; a Data Processor processes it on the Fiduciary's behalf.
What is Data Fiduciary and Data Processor?
The operator who collects traveller details, decides what to collect and why, and runs the trip is the Data Fiduciary. The obligations to give notice, obtain consent, secure the data, honour rights requests and handle grievances sit with the Fiduciary. Software the operator uses to store and act on that data is a Data Processor acting under a contract.
The distinction decides who answers to the traveller. A traveller asking for their data to be deleted asks the operator; the operator's tools must make that possible.
On a live trip
Know which role you hold for each piece of data, put it in writing with your software providers, and make sure deletion requests can actually be carried out across every tool the trip used.
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