
This actor analysis checklist contains questions to help organisations determine their relevant actor characterisations as data fiduciaries or data processors under the Digital Personal Data Protection Act, 2023. This is a necessary exercise since the law prescribes different functions and obligations for different classes of entities. Identification of the specific category that an organisation falls into, is a fact-based assessment that depends on the data processing activities conducted by it. This template can be used to record an organisation’s findings, and can further be customised and expanded to reflect the unique requirements of its business model.
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