Should a data processing agreement be concluded with a person employed under a civil law contract?

ANSWER

If a data controller engages natural persons under civil law contracts (contract for specific work, mandate contract, etc.), it should treat those persons like other employees employed under employment contracts and grant them authorisations to process personal data.

However, if those persons run sole proprietorships and process personal data on behalf of the data controller, they should do so on the basis of a data processing agreement. This is already a relationship between two entrepreneurs.