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Answer:
The EU GDPR toolkit https://advisera.com/eugdpracademy/eu-gdpr-documentation-toolkit/ is designed to be used by both controllers and processors and most of the document reflect this. However, there are certain sections that are less relevant for processors such as the Managing Data Subjects Rights and the Data Protection Impact Assessments because these are more controller oriented.
Bear in mind that any company established in EU is unlikely to be only a processor regardless of its business activities, if it has employees it will act as a controller in terms of processing their data .
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Mar 27, 2018