Gdpr Data Sharing Agreement Between Controllers

Here, too, just because a situation like this can exist does not predetermine a common controller status. The definition depends on whether those responsible jointly determine the purposes and means of treatment. Article 28.4 states that the same data protection obligations apply even when a subcontractor assigns another subcontractor to specific processing activities on behalf of the processing manager. In the event of an infringement, the article states: “If this other subcontractor does not comply with its data protection obligations, the first processor is fully responsible for fulfilling the obligations of that other subcontractor to the person in charge of the processing.” You need to think carefully about where this applies, as it may not be obvious that you have data on a processor as a controller. For example, storing certain personal data on a cloud storage service would likely fit this definition, since personal data is processed by an external third party (processor) (stored on servers), even if that company does not have direct interaction with the data. In other cases where the recipient of the data is another person responsible for processing and not a common person responsible for processing, it is up to the processing manager to jointly determine the data necessary to comply with the provisions of the RGPD and protect the privacy of individuals. LocalActivities is responsible for the processing because it has opted for the purposes and means of using personal data, i.e. to collect registration information for an event they organized. An assessment of legitimate interests is a three-step test to determine whether you really have a legitimate interest in processing, the need for treatment to achieve your legitimate interest and whether the rights and freedoms of the individuals concerned outweigh your interest, in which case you could not invoke the legitimate interests of the treatment and you should obtain the consent of the persons concerned. You will find an evaluation form for legitimate interests in my RGPD compliance package, on which you are under/www.suzannedibble.com/gdprpack We have not agreed on model sharing, as there is a wide range of possible inclusions and levels of detail, and it would not be possible to meet all needs in a user-friendly manner. In other cases, the terms of use of the data processor may include or refer to a contract covering the necessary clauses, especially in the case of online web services that you could use.