Data Fiduciary
A Data Fiduciary is any person who, alone or with others, determines the purpose and means of processing personal data. The Act's obligations fall primarily on this role.
Engaging a Data Processor to handle the work does not transfer the obligation — the fiduciary remains answerable for the personal data. Many organisations are a fiduciary for some data and a processor for other data at the same time.
General information about the DPDP Act, not legal advice.