Are You a Significant Data Fiduciary? Free DPDP SDF Classifier
Seven questions drawn from the Section 10(1) factors.
Answer seven yes/no questions based on the factors in Section 10(1). The classifier estimates your likelihood of SDF designation.
Methodology & assumptions
This note is published as a working draft so the reasoning is open to scrutiny. The figures and section references come from the tool itself; the interpretation around them has not yet been signed off.
How the result is calculated
Each question carries a weight of two or three, according to how directly it maps to a Section 10(1) factor. A 'yes' adds its weight, and the score is shown as a percentage of the maximum of eighteen. Under 35% reads as unlikely, 35 to 64% as possible, and 65% or more as likely. All seven must be answered before a verdict appears.
Statutory basis
Section 10(1) lets the Central Government notify any Data Fiduciary as Significant, having regard to the volume and sensitivity of personal data processed, the risk to Data Principals' rights, and the potential impact on the sovereignty and integrity of India, electoral democracy, the security of the State and public order. The obligations that follow designation are in Section 10(2) and Rule 13.
Assumptions and limitations
The weights are our own reading of which factors carry most weight, not a published formula, and the tool treats them as additive. SDF status is conferred by notification, not calculation, and none have been notified so far, so there is no precedent to calibrate against. A high score means plan for Rule 13 now; a low score is not an assurance. Information, not legal advice.