Guest user Created: Sep 06, 2018 Last commented: Sep 06, 2018

Data processing agreement

We are a company recruiting seafarers that we could use to supply a vessel that is required by our customers. We have a customers who's giving us information what position we need to fill in. In this case, there is a scenario where we share information of the seafarers to our customers and we don't know if they are also sharing those info outside their company for whatever purposes. Our question is, do we need a data processing agreement with our customers or we should be treated as two independent controllers or what agreement should we use?

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Andrei Hanganu Sep 06, 2018

Answer:

Based on your description both you and the company that would hire the seafarers are acting as independent controllers. Except for the instance where the hiring company would provide you with the data of somebody for you to contact and interview on your behalf.

In the independent controller scenario, although is not strictly mandated by the GDPR, you could have a Controller to Controller GDPR Addendum (we are working in developing such a template) and for the scenario where you would be a processor, the hiring company would most likely ask you to sign a Supplier Data Processing Agreement similar to the one in our EU GDPR Documentation Toolkit ( https://advisera.com/eugdpracademy/eu-gdpr-documentation-toolkit/ )

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Sep 06, 2018

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