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Category: Controller/Processor

Whose Decision is it Anyway?

Controller/Processor determinations

(a.k.a how a data protection anorak spends their leisure time)

Following a lot of pre-GDPR kerfuffle online about Data Controller/Data Processor relationships (and the varying degrees to which these are direly misunderstood), I spent a geeky Sunday night putting together a decision tree tool which should – hopefully – help people who are getting confused/panicked/deeply weary of the search for answers.

It’s not intended to be legal advice, it’s not formal advice from me as a consultant and it’s not guaranteed to be absolutely 100% perfect for every possible scenario. It’s designed for the low-hanging fruit, the straightforward relationships (like standard commercial supply chain) rather than the multi-dimensional nightmare data sharing behemoths one tends to find in the public sector.

Anyway, here it is. Enjoy. If you like it, please tell others where to find it. If you have constructive criticism (that’s not “oh you missed out this incredibly niche complex scenario that would only ever happen every 100 years”) please tell me.

The Tool

 

Here are also some useful links:

https://ico.org.uk/media/about-the-ico/consultations/2014789/draft-gdpr-contracts-guidance-v1-for-consultation-september-2017.pdf

http://ec.europa.eu/justice/article-29/documentation/opinion-recommendation/files/2010/wp169_en.pdf

Who’s in Control?

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