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Data processors

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Guest user Created:   Feb 23, 2018 Last commented:   Feb 23, 2018

Data processors

Is there a version of the GDPR document package, or additional documents that are intended for data processors? I purchased the original EU_GDPR_Documentation_Toolkit, but I really only see documents for data controllers.
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EU GDPR DOCUMENTATION TOOLKIT

Step-by-step implementation for smaller companies.

EU GDPR DOCUMENTATION TOOLKIT

Step-by-step implementation for smaller companies.

Expert
Andrei Hanganu Feb 23, 2018

Answer:

It is very unlikely that you are only a processor. If you are based in the EU and you have employees this makes you a controller in terms of processing their personal data at least for the purpose of HR management.

Regardless, assuming that you are acting solely as a processor the only folder of the toolkit that will not be suitable for you are “04_Managing_Data_Subject_Rights” and “05_Data_Protection_Impact_Assessment”.

You may also need to tweak a little the “9.1_Data_Breach_Response_and_Notification_Procedure_EN” because as a processor you only are required to notify the data controllers about the data breach and you are not allowed to contact the Supervisory Authority or the data subjects. If your customers acting as controllers don’t have specific requirements as regards to what information to provid e them when a data breach occurs you can use the template for “9.3_Data_Breach_Notification_Form_to_the_Supervisory_Authority_EN” to inform the controller about the breach (just remove the “TO THE SUPERVISORY AUTHORITY “ from the title).
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Feb 23, 2018

Feb 23, 2018

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