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Glossary · Finance and compliance

Data processor

A data processor is the company or person that processes personal data on behalf of another—the controller—and following its instructions: the hosting provider, the payroll firm or the email tool.

Data processor: the details

The distinction matters because it splits the obligations. The controller decides why and how the data is used and answers to the people affected. The processor may only do with it what the controller has instructed. Article 28 of the GDPR requires that relationship to be set out in a contract detailing the subject matter, the duration, the type of data, the security measures and what happens to the data at the end.

The processor can’t subcontract without authorization, must help the controller respond to people’s rights and has to notify it without undue delay if it suffers a breach. When you buy cloud software or AI services, your company is normally the controller and the vendor is the processor: before sending it personal data you need that contract and you need to know where the data is processed.

Data processor in a project

In a project with personal data, the first step is to write down who is the controller and who is the processor for each activity, which providers are involved and in which region each one processes.

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