Guest user Created: Mar 30, 2018 Last commented: Mar 30, 2018

Data Processor Addendum

I have a question on whether we would require to sign a Data Processor Addendum that Customers are requesting. We supply Reporting Software, we are not a cloud based solution and request a users name/email address when they register to use the application for the first time. We also provide a Support Portal (online) that requests a separate name/email address for access. One other element is that our products can send back product usage information identified by the person using the product (this is optional by the user).

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Andrei Hanganu Mar 30, 2018

As we are a reporting tool, the above PII is the only information we request from our customers and store this information in Salesforce (Salesforce is a data processor to us).

We are being requested to sign a Data Processor Agreement with our customers and believe we are more of a Data Controller in this instance. Could you clarify.

Answer:

My understanding is that you are providing a Reporting Software to customers that would be required to register with a username and email so start using the software. For th is instance you are a controllers because you are determining what information is required from a customer to register.

I assume that the reporting software is addressed to companies rather than individuals. In this instance if the companies as your customer would use the reporting software to process personal data of their individual customers that would make you a processor when providing for example hosting and/or maintenance.

To find out about controllers and processors you can check out our article “EU GDPR controller vs. processor – What are the differences?” - https://advisera.com/eugdpracademy/knowledgebase/eu-gdpr-controller-vs-processor-what-are-the-differences/

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Mar 30, 2018

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