Legal Register
Control Workpaper
OBL-32 Section 10(1) — designation-dependent SDF status ACT-10

OBL-32: Significant Data Fiduciary Assessment (Section 10(1))

Assesses processing volume, sensitivity, and national security factors against SDF designation.

Statutory scope: Section 10(1) — designation-dependent SDF status · Assigned to Privacy / accountable sponsor · Systems: Governance source register

Operational Interface Requirement

Recommended interface: Remove the applicable designation notification; expected outcome is not_designated in the base case, with voluntary readiness separately labelled.

Expected Audit Assertion / Test Result

Remove the applicable designation notification; expected outcome is not_designated in the base case, with voluntary readiness separately labelled.

Governance & Architecture

Recommended Activity Owner
Privacy / accountable sponsor
Target Systems & Interfaces
Governance source register

Verification Specification & Workpaper

Proposed Test Specimen ID
SPEC-Q10-OBL-32

proposed per-row review/acceptance specification; not a claim of executed statutory coverage

Populated Teaching Workpaper
out/remediation/Q05/sdf-readiness.json

populated hypothetical decision/specimen; not actual enterprise execution

Local Execution Reference
out/dossier/CASE-001/tests/results.json

Canonical Statutory Grounding

Source references verified against the official Gazette of India publication baseline.

ACT-10 Lines 404–438
Commencement: 2027-05-13 (scheduled, not yet operative)
Obligated Actor

Central Government; notified SDF

Trigger Context

Notification of fiduciary or class following relevant-factor assessment

Statutory Conditions

India-based individual DPO responsible to governing body; independent auditor; periodic DPIA/audit and prescribed measures.

Statutory Exceptions

Not automatic from scale/sensitivity; designation and effective timing matter.