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A Data Fiduciary determines the purpose and means of processing; a Data Processor processes personal data on behalf of, and under the instructions of, a Data Fiduciary. Obligations differ materially by role.
Personal data is any data about an individual who is identifiable by or in relation to such data. This determines whether the Act applies.
The Act permits cross-border transfers except to countries restricted by Government notification. General data localisation is not required, but restricted destinations and any sector-specific limits must be tracked.
This includes dependents of employees and data processed through education, gaming, healthcare, or similar services. It triggers heightened obligations.