Module 02 — Data principal rights + Fiduciary obligations
Goal: Map every right + obligation to a practical action.
Rights of data principals (§11-§14)
§11 — Right to information about processing (similar to GDPR Art. 15)
§12 — Right to correction + erasure (similar to Art. 16-17, but with limits)
§13 — Right to grievance redressal — file with Fiduciary first; escalate to DPB
§14 — Right to nominate — appoint another individual to exercise rights upon death/incapacity
Notably absent: data portability, right to object to processing (compared to GDPR).
Obligations of fiduciaries (§8)
Every Fiduciary must:
Process for lawful purpose only
Implement reasonable security safeguards
Notify the DPB + affected data principals of breaches
Erase data when purpose is fulfilled (and inform Processors)
Publish business contact for grievance officer
Significant Data Fiduciary additional obligations
SDFs (notified by Government):
Appoint Data Protection Officer (DPO) based in India
Conduct Data Protection Impact Assessment (DPIA) for high-risk processing
Conduct periodic audits by independent Data Auditors
Likely SDFs: large e-commerce, healthcare aggregators, banking, telco.
Children's data (§9)
Verifiable parental consent required for processing children's data (<18)
Cannot do tracking, behavioural monitoring, targeted advertising at children
Cannot cause harm to children
DPB can exempt platforms that demonstrate verifiable safe processing
Cross-border transfer (§16)
Default: data can flow to any country EXCEPT those notified as restricted by Central Government.
This is more permissive than GDPR's adequacy decisions. The restricted list (when notified) becomes the bottleneck.
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Last reviewed: 24 April 2026.