General

    As a brand using CRM, loyalty platforms, and marketing tools, who is responsible if there is a compliance failure?

    Answer

    Your organization is the Data Fiduciary, meaning you are responsible for determining how and why data is used. Even if vendors process data, the liability remains with you.

    This means you must actively manage vendors, internal teams, and systems to ensure compliance — responsibility cannot be outsourced.

    Law Reference

    Section 2(i) – Definition of Data Fiduciary

    "Data Fiduciary means any person who… determines the purpose and means of processing."

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