Under India's DPDP Act 2023, the Data Fiduciary remains accountable for personal data even when a processor handles it. TPRM in 2026 means assessing vendors' DPDP posture, signing and tracking Data Processing Agreements, scoring vendor risk and monitoring sub-processors — best managed with TPRM software.
Why vendor risk is your risk
Sharing personal data with a processor doesn't transfer accountability. If a vendor mishandles data, the Data Fiduciary can face the penalty — making vendor due diligence essential.
DPAs and assessments
Govern every processor with a Data Processing Agreement and assess their DPDP posture before and during the relationship. Track DPAs and renewals so nothing lapses.
Don't forget sub-processors
The fourth parties behind your vendors carry risk too. Maintain a sub-processor registry and monitor continuously.
FAQ
Under the DPDP Act, the Data Fiduciary remains accountable for personal data even when processed by a vendor, which is why third-party risk management and Data Processing Agreements are essential.