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DPDP Sec. 10(1) · 5 statutory factors · 12 signals

Significant Data Fiduciary (SDF) Classification Checker

SDFs face DPO, DPIA, and audit obligations (Sec. 10(2)) that ordinary Data Fiduciaries do not. This tool walks the five Sec. 10(1) statutory factors, weights each signal, and returns your SDF probability with a full reasoning trace and a memo you can send your Board.

Live signal weighting
Volume
12
Sensitivity
8
Cross-border
6
Electoral
0
CII / Sec.
3
SDF probability
62%

Factor 1 — Volume & Sensitivity of Personal Data

DPDP Sec. 10(1)(a)–(b)
< 1 lakh
Yes, primary
Yes, primary segment

Factor 2 — Risk to Sovereignty & Integrity of India

DPDP Sec. 10(1)(c)
Yes, routinely
Yes

Factor 3 — Risk to Electoral Democracy

DPDP Sec. 10(1)(d)
Yes
Yes

Factor 4 — Risk to Public Order & Security of the State

DPDP Sec. 10(1)(e)
Yes
Yes

Factor 5 — Business Model & Regulator Attention

Draft Rules commentary + MeitY consultation signals
Yes, core
Yes
Please answer all 12 signals. item(s) still need an answer. We scrolled to the first one for you.

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Why this matters

SDFs must:

  • Appoint an India-based DPO (Sec. 10(2)(a))
  • Appoint an independent data auditor (Sec. 10(2)(b))
  • Conduct periodic DPIAs and audits (Sec. 10(2)(c))
  • Meet additional Rule 12–13 obligations once notified
The Central Government notifies SDFs by class under Sec. 10(1). Weights here reflect the statutory factors and 2025 draft Rules commentary, not the final notified thresholds.
SDF Probability
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Reasoning trace

Each signal that contributed to your score, ranked highest to lowest impact.

If notified as SDF, you must

Prepare for SDF in dcomply →