Tag Archives: processors

How to engage processors

Articles 28 and 29 of the GDPR require a “by a contract or other legal act” in order to engage a processor. Such document must include: the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects; the confidentiality agreement; assurance that… Read More »

Processors and sub-processors

Current Directive 95/46/EC does not regulate sub-processing. A controller can choose a processor, but a processor cannot choose a sub-processor. As a result, many processors chose sub-processors and designated them as their own processors. These cases should have been discussed in the last 20 years, considering that supply chains are getting longer. The last GDPR… Read More »