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Vendor and processor review checklist
Under the DPDPA, using a vendor to process personal data doesn't transfer your responsibility for it. A data fiduciary generally remains accountable for how a processor handles data on its behalf. This checklist is a starting point for questions worth asking before, and after, a vendor comes on board.

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Before you sign
Contract terms to include
Ongoing oversight
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The provisions this guide draws on — official text, in English.
- Section 8(1), (2), (5), (6) and (7) · DPDP Act, 2023General obligations of Data Fiduciary
- Section 16 · DPDP Act, 2023Processing of personal data outside India
- Rule 6(1) · DPDP Rules, 2025Reasonable security safeguards
- Rule 7 · DPDP Rules, 2025Intimation of personal data breach
- Rule 8(3) · DPDP Rules, 2025Time period for specified purpose to be deemed as no longer being served
- Rule 15 · DPDP Rules, 2025Transfer of personal data outside the territory of India
Curious what this looks like in practice? We publish our own sub-processor list and Data Processing Addendum.
See our sub-processors