Any person or entity that processes personal data on behalf of a Data Fiduciary under contract.
A Data Processor processes digital personal data on behalf of a Data Fiduciary, acting only on the Fiduciary's instructions. The Processor does not determine the purpose of processing — they execute what the Fiduciary directs. Under DPDPA, the Data Fiduciary remains ultimately liable for the Processor's actions. A valid Data Protection Agreement must govern this relationship.
Every third-party vendor handling your customer data is a Data Processor. You remain liable for their compliance failures, making vendor due diligence and contractual safeguards essential.
A Hyderabad e-commerce startup uses a third-party payment gateway and a cloud CRM. Both are Data Processors. If the CRM vendor suffers a breach exposing customer data, the startup (as Fiduciary) must notify the Board and affected principals.
Startups often think using a "big brand" processor like AWS absolves them of liability. Under DPDPA, the Fiduciary is always accountable regardless of the processor's reputation.
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