Short Answer
Yes, as the Data Fiduciary, your company remains responsible even if the breach originates from a vendor or third-party system.
Yes, your company remains responsible because you are the Data Fiduciary. Even if the breach originates from a vendor, the accountability does not shift.
This is why businesses must ensure strong vendor governance, contracts, and monitoring mechanisms. You are expected to ensure that your entire ecosystem follows DPDP standards.
Law Reference
Section 8 – Obligations of Data Fiduciary
Vendor governance becomes critical. Businesses must enforce DPDP standards across their entire ecosystem through contracts, audits, and monitoring.
A retailer's SMS vendor suffers a breach exposing customer phone numbers. The retailer, not the vendor, faces regulatory action as the Data Fiduciary.
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