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ARTICLE · 19 DECEMBER 2019

The Personal Data Protection Bill 2019 - A Comparison With The 2018 Bill

Argus Partners
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In the 2018 Bill, the definition of "data processor" specifically stated that it did not include an employee of a data fiduciary.

IndiaPrivacy
Vinod Joseph
Vinod Joseph
Protiti Basu
Protiti Basu
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Introduction

The latest version of the Personal Data Protection Bill, 2019 ("2019 Bill") has been in the public domain since December 10, 2019 and we have compared the latest version against the Personal Data Protection Bill, 2018 ("2018 Bill").

Significant Changes

The clauses have been shuffled and a number of drafting changes have been made, making it difficult to cull out the significant changes, such as the following:

1. Status of employees of data fiduciaries: In the 2018 Bill, the definition of "data processor" specifically stated that it did not include an employee of a data fiduciary. The 2019 Bill does not have the same carve-out for employees of data fiduciaries. Does this mean employees of data fiduciaries shall bear the same responsibilities and obligations as data processors? If an employee of a data fiduciary were to be treated as a data processor, such employees would have to implement security safeguards, carry out periodic review of security

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