What makes a GDPR process unique?
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Answer:
It is not necessarily about the types and categories of personal data even if these are the same for more than one process, it is about the other elements that must be identified such as lawful basis, retention period, etc. You can have the exact same sets of personal data in two processes but the lawful basis for processing would be different. For example, the personal data of employees is usually processed using contractual obligation or legal obligation and the data of customers (even if we are talking about the same set of data) could be processed based on consent. Also, the retention period may differ. So, as you can see, there is a good reason for having a process-centered approach.
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Jan 15, 2019