The underlying rationale for a structured digital database as explained by Dr T.K.Viswanathan Committee is that once the information is shared with outsiders, the company has no control over it. Therefore, the company would need to keep a track of the first set of external recipients so that a trail can be established if need be.
However, while tracking external sharing of information is clearly critical, it would be difficult or nearly impossible without ensuring control over the sharing of UPSI by multiple internal people from where the information trail may split.
Hence, SEBI in its Comprehensive FAQs provides that SDD is required to be maintained irrespective of the fact that information is shared within or outside the Company, requisite records are required to be updated in SDD as and when the information gets transmitted.
