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Transfer to controllers or Processors - which one to use?

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Guest user Created:   Sep 01, 2020 Last commented:   Sep 02, 2020

Transfer to controllers or Processors - which one to use?

We are the software developing company and wanted to fill out the SCCA
Which one do we need to use? Transfer to controllers or Processors? We would be transferring the information to our contractor software company in India from the USA

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Step-by-step implementation for smaller companies.

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Alessandra Nisticò Sep 02, 2020

I would need more information. It depends on who processes personal data. The processor collects and processes personal data on behalf of the controller, according to the article 28 GDPR. So if the contractor software company will process data on your behalf, you will be the controller and the contractor will be the processor.

On the contrary, if you are developing a software and license it to the contractor who will processes data on its own behalf and on its own servers, the contractor will be the controller and you might be the processor if you have any access to personal data (i.e. for maintenance reason).

You can also find more information here:

You can consider enrolling in our free EU GDPR Foundations Course

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Sep 01, 2020

Sep 02, 2020