General obligations of Data Fiduciary

Fiduciary is responsible for processing carried out by it or on its behalf by a Processor. Must ensure data accuracy, implement security safeguards, notify Board and affected principals of breaches, erase data on withdrawal of consent or once purpose is served (unless retention is legally required), and publish business contact info for grievances.

Cross-cuts almost every module: Vendor contracts, Incident response (breach notification), Retention/erasure jobs, Grievance Officer in Settings.