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

Multi controllers

We have business relationships in which we are neither processor nor joint-controller in relationship to the other business. We are data controllers in common, as the term seems to be. I don’t see an agreement for multi-controller relationships of that nature in the Advisera GDPR documents, however. Is there a modification of an existing document that makes it suitable for a multi-controller relationship? Or do you have a different document for that to provide us?

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Andrei Hanganu Aug 23, 2018

Answer:

“Controllers in common” or “independent controllers” are both processing personal data but independently and for different purposes and there is no requirement to have a document stating their obligations as they are both bound by the controller obligations under GDPR. The GDPR only requires to have such document between controllers and processors or between joint controllers.

This is the reason for which we don`t have such a document in the toolkit. Please no te that the Supplier Data Processing Agreement is not suited to be used in a controller to controller situation.

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Aug 23, 2018

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