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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)

Factor 2 — Risk to Sovereignty & Integrity of India

DPDP Sec. 10(1)(c)

Factor 3 — Risk to Electoral Democracy

DPDP Sec. 10(1)(d)

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

DPDP Sec. 10(1)(e)

Factor 5 — Business Model & Regulator Attention

Draft Rules commentary + MeitY consultation signals

Result computed in your browser. Nothing is sent to a server.

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 →