Fintech Startups
Liability Check
Fintechs handling KYC Data, Aadhar Numbers, and Payment Ledgers are classified as 'Significant Data Fiduciaries' with higher compliance burdens.
Why Fintech Startups is at Risk
As a Fintech, you likely process sensitive financial data and ID proofs. The Central Government may classify you as a **Significant Data Fiduciary (SDF)** based on the volume and sensitivity of data. SDFs must appoint a Data Protection Officer (DPO) based in India and conduct periodic Data Protection Impact Assessments (DPIA) and independent data audits.
Common Violations
- 1.Storing unmasked Aadhar numbers or KYC documents on unsecured cloud servers (S3 buckets).
- 2.Collecting excessive data (e.g., contact lists) for loan underwriting without specific consent.
- 3.Failure to appoint an independent data auditor as required for Significant Data Fiduciaries.
The Immediate Fix
Appoint a **Data Protection Officer (DPO)** immediately if you haven't. Implement a grievance redressal mechanism that can respond to user complaints within the prescribed timeline (usually 7 days).
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Need help checking your business?
- Start with the free self-check to find questions for your team.
- Our paid gap assessment takes four weeks. We check your apps, documents and records, then list what needs fixing.
- Fixing the agreed gaps takes two to three months. A final assessment checks the completed work.
Save your results and discuss the questions with your team.
Next step after the audit
The audit shows the gaps. Sanctum closes them. One programme covers legal position, data map, gap analysis, implementation, tooling, training, a written readiness opinion, and breach cover, under one accountable owner. See the all-in-one programme
What Should You Do Next?