Data fiduciary obligations require processor contracts, data accuracy, security safeguards, breach notices, erasure, contact disclosures and grievance redressal.

Data Fiduciaries remain responsible for compliant personal-data processing undertaken by them or by Data Processors, who may be engaged only under valid contracts. They must maintain data quality for consequential decisions or disclosures, implement technical and organisational compliance measures, maintain reasonable security safeguards, and notify the Board and affected Data Principals of breaches. Personal data must be erased on consent withdrawal or when its purpose ends, unless legal retention is required, including erasure by Data Processors. They must also publish appropriate contact information and provide effective grievance redressal.

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