Separate Data Controllers Agreementadmin
Before we address the complex issue of multi-control situations in the RGPD, we must first understand the primary responsibilities of a person in charge of treatment in general. In accordance with Section 30 of the RGPD, processing managers must keep a record of their data processing activities. Common governance takes place only in certain situations where the two leaders decide together (and thus together) the means and purposes of the treatment. Decisions are made together and share responsibility for the processing of personal data. As I said, Article 4 of the RGPD stipulates that the purposes and means of data processing can be determined by one person in charge of the processing or with others – the subsequent case is what is called a common controller relationship. A common controller relationship is therefore that two or more processing managers jointly determine the means and purposes of data processing activities. Joint treatment managers have the same obligations as all other treatment managers, as noted above, with the addition of section 26 of the RGPD. Article 26 of the RGPD requires co-responsible to enter into an agreement or agreement (for example. B an agreement on the common controller) regulating their respective responsibilities and obligations under the RGPD. EC article on the controller processor (with an example of articulation regulator!) As in a common controller scenario, controller-to-controller relationships also involve the presence of two or more fogs. However, in this case, the data of the separate data managers is shared, but treats them individually for their own individual and different purposes.
Although treatment managers have the same general obligations as all other treatment managers, members of a relationship between treatment managers are not legally required to enter into an agreement or agreement between them, as do joint treatment managers, although this is often helpful. And of course, WP29 reviews v processors with a decent bit on common control. That is why section 26 of the RGPD requires common officials to make clear arrangements as to who is responsible for what. And while Article 26 does not require a written agreement, it can be difficult to respect the principle of accountability and to draw up differences of opinion in the absence of a written agreement. 1.2 A person is a natural person, entity or community (whether or not he or she has his or her own legal personality). A luxury car company is working with a designer fashion brand to organize a promotional event with co-branding. Companies opt for a draw at the event. They invite participants to participate in the draw by typing their name and address into their draw system. After the event, the company awards the prizes to the winners. You do not use personal data for other purposes. If you are solely responsible for the data of a processing activity, you and you are solely responsible for compliance. The same is not true for multi-control scenarios.
In addition, joint controllers are fully accountable to the supervisory authorities (for example. B.dem ICO) for not respecting their responsibilities.