Guest user Created: Mar 18, 2019 Last commented: Mar 18, 2019

EU GDPR and volunteers

1. We purchased your GDPR toolkit some time ago. We are an international non-profit membership organization with paid staff and volunteers. I have a somewhat unique situation that I'm not sure which documents in the toolkit to utilize for this situation. The main office of our organization is headquartered in the United States. We have various special interest groups located in different countries, including the EU region. The special interest groups are ran by volunteers and are a branch of the main office. Are we able to transfer data of our members to our volunteers in the region so that they can contact them directly about events?

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Andrei Hanganu Mar 18, 2019

Answer: Each of the EU branches of your organisation should have in place a Controller to Controller Data Transfer Agreement with the US Headquarter (document 7.1 in the EU GDPR Documentation Toolkit).

2. What forms do our volunteers need to sign so we can transfer the data to them? I'm not finding something applicable in the templates we purchased. It would be a cross-border transfer to one of o ur volunteer members but we do not have a commercial agreement with our volunteers. Sometimes at events, our volunteers would be data controllers on behalf of the organization as well but I am specifically asking about data transfer from our headquarters to our volunteer leaders in the EU region, and our volunteers would contact the members directly on behalf of the organization.

Answer: The volunteers would act as your processor and should be treated as such. You would need to have a DPA in place (document 8.1 of the EU GDPR Documentation Toolkit) .

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Mar 18, 2019

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