may also enter into a memorandum of understanding with such other regulator or authority governing the coordination of such actions. 68. Appointment of Adjudicating Officer.— (1) Without prejudice to any other provision of this Act and for the purpose of imposing of penalties under section69to section 73or awarding compensation under section 75, the Authority shall have a separate adjudication wing. (2) The Central Government shall,having regard to the need to ensure the operational segregation, independence, and neutrality of the adjudication wing,prescribe— (a) (b) (c) (d) (e) (f) (3) number of Adjudicating Officers; qualification of Adjudicating Officers; manner and terms of appointment of Adjudicating Officers ensuring independence of such officers; jurisdiction of Adjudicating Officers; procedure for carrying out an adjudication under this Act; and other such requirements as the Central Government may deem fit. The Adjudicating Officers shall be persons of ability, integrity and standing, and must have specialised knowledge of, and not less than seven years professional experience in the fields of constitutional law, cyber and internet laws, information technology law and policy, data protection and related subjects. CHAPTER XI PENALTIES AND REMEDIES 69. Penalties.— (1) Where thedata fiduciary contravenes any of the following provisions, it shall be liable to a penalty which may extend up to five crore rupeesor two per cent of its total worldwide turnover of the preceding financial year, whichever is higher, as applicable— (a) (b) (c) (d) (e) obligation to take prompt and appropriate action in response to a data security breach under section 32 of this Act; obligation to undertake a data protection impact assessment by a significant data fiduciary under section 33 of this Act; obligation to conduct a data audit by a significant data fiduciary under section 35 of this Act; appointment of a data protection officer by a significantdata fiduciaryundersection 36 of this Act; failure to register with the Authority under sub-section (2) of section 38. 41

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