Q2 - Can a single organization act as a Data Fiduciary for one activity and a Data Processor for another?

Yes. A single organization can wear both hats, depending on the context of processing.

Example

ABC Payroll Pvt. Ltd. has two roles:

• For its own employees, it collects resumes, salary details, and attendance records. Here, it is the Data Fiduciary because it decides why this data is needed.
• For its clients, it processes employee salary slips and tax information strictly as per the instructions of those clients. Here, it becomes a Data Processor, because the client companies remain the Data Fiduciaries.

This dual role is common in outsourcing, IT services, and cloud hosting arrangements.