The classification of data
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Answer:
Personal data that should be protected regardless of which structure within the company or third party processes it. Internally, the whole company is responsible and assigning an owner will only cause confusion and spread the belief that only the owner is accountable for how the personal data is being processed. Ultimately, the company is responsible if the data i s processed in an unlawful manner and not a specific individual/employee.
In terms of your web developer, as he will be acting as your data processor, he is bound by the obligations set up in Article 28 of EU GDPR and you, as a data controller, need to ensure that those obligations are clearly set out in the Data Processing Agreement you need to sign with the processor.
To learn more about processors and controllers, as well as the responsibility of managing personal data, check out this free EU GDPR Foundations Course (https://advisera.com/training/eu-gdpr-foundations-course//).
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Dec 12, 2018