GDPR questions and answers

GDPR: QUESTIONS AND ANSWERS

Category:
Data Processing

Where 2 or 3 controllers exist in an organisation, is it possible for them to maintain joint records of processing activities where some processing activities are identical for them?

ANSWER

Each controller should maintain its own record, for the sake of accountability. Thus joint controller A should have processing activity XYZ in its record, joint controller B should have processing activity XYZ in its record, and joint controller C should have processing activity XYZ in its record.

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