Glossary
Data processor
A person that processes personal data on behalf of a data fiduciary, whose processing remains the fiduciary's responsibility under the Digital Personal Data Protection Act, 2023.
Under section 2(k) of the Digital Personal Data Protection Act, 2023, a data processor is a person who processes personal data on behalf of a data fiduciary. Under section 8(1) of the Digital Personal Data Protection Act, 2023, the data fiduciary remains responsible for compliance with the Act for processing done on its behalf by a processor, irrespective of any agreement to the contrary.
The fiduciary therefore carries its duties down the chain by contract. Section 8(5) requires reasonable security safeguards, including for processing by a processor, and rule 6 of the Digital Personal Data Protection Rules, 2025 requires the contract with a processor to oblige it to take the named security measures. Both start on 13 May 2027. An indemnity from a processor may move the cost of a failure; it does not move the responsibility. The position is stated as at 9 October 2026.
Used in
- A telemedicine product in India answers to three regulators at once, and only the doctor may prescribe
- Location and driving data from a vehicle telematics device is personal data under the DPDP Act from 13 May 2027
- An AI vendor's indemnity moves the money, not the responsibility: contracts, diligence and disclosure
- The DPDP Rules are notified, and almost nothing in them binds until 13 May 2027
- The DPDP exemption for schools and universities covers tracking and behavioural monitoring, not every use of a student's data
Sources
- ActThe Digital Personal Data Protection Act, 2023 (No. 22 of 2023)meity.gov.inOn this site: The Digital Personal Data Protection Act, 2023
- RulesDigital Personal Data Protection Rules, 2025, G.S.R. 846(E), 13 November 2025, Gazette of India Extraordinary, Part II, Section 3, Sub-section (i), Ministry of Electronics and Information Technologymeity.gov.inOn this site: Digital Personal Data Protection Rules, 2025
Cite this termData processor. Juris Eagle glossary. Stated as at 9 October 2026. https://juriseagle.com/glossary/data-processor