Glossary
What is a data auditor under DPDP?
A data auditor is an independent auditor that a Significant Data Fiduciary must appoint. Other Data Fiduciaries are not required to have one.
Definition
A data auditor is the independent data auditor that a Significant Data Fiduciary must appoint under s.10(2)(b) of the DPDP Act, 2023. The SDF must also carry out a periodic data audit (s.10(2)(c)), and Rule 13 requires an audit once every twelve months with significant observations furnished to the Board. S.O. 5458(E) of 6 October 2026 changed “audit” to “data audit” in s.10(2)(c)(ii) and adds no new duty.
What it means
The data auditor duty attaches to SDF status. The Act requires the auditor to be independent; check with counsel what that means for your structure.
The Removal of Difficulties Order is editorial: the audit duty was already in s.10(2)(c), and the Order only aligned the wording to “data audit”. See Rule 13.
Where it appears in the Act and Rules
| Provision | What it says |
|---|---|
| s.10(2)(b) | Appoint an independent data auditor |
| s.10(2)(c) | Periodic DPIA, periodic data audit and other measures |
| Rule 13 | DPIA and audit once every twelve months; significant observations furnished to the Board |
| S.O. 5458(E) | “Audit” becomes “data audit” in s.10(2)(c)(ii); editorial only |
Common misconceptions
- “The October 2026 Order created the data audit.” The Order only changed a word; the audit duty was already in s.10(2)(c).
- “Every Data Fiduciary needs a data auditor.” Only SDFs, under s.10(2)(b).
- “Any auditor will do.” s.10(2)(b) requires an independent data auditor; confirm independence with counsel.
Related terms
A Data Fiduciary the Central Government notifies for extra duties (s.10).
Data Protection OfficerThe India-based officer a Significant Data Fiduciary appoints (s.10(2)(a)).
Data Protection BoardThe Board established under s.18; no members appointed yet.
Data FiduciaryDecides the purpose and means of processing personal data (s.2).
In TruePrivacy
The SDF workspace records the independent data auditor and runs yearly clocks for the DPIA, the data audit and algorithmic due diligence, which start once you record the designation. The audit trail logs every action with before and after values and exports as CSV for review.
Who must appoint a data auditor?
A Significant Data Fiduciary, under s.10(2)(b). Other Data Fiduciaries are not required to.
How often is the audit done?
Rule 13 requires an SDF to carry out a DPIA and an audit once every twelve months and furnish significant observations to the Board.
What did S.O. 5458(E) change?
It changed “audit” to “data audit” in s.10(2)(c)(ii) and inserted “of” in s.9(1). It is editorial only and adds no new duty.
Your DPDP plan, starting today
Core obligations for data fiduciaries begin on 13 May 2027.
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