What status does a Social Housing Committee have?
ANSWER
A social housing committee will not constitute an independent data controller within the meaning of Article 4(7) GDPR. A social housing committee is a team or advisory and/or consultative body of a commune head (wójt), mayor (burmistrz) or city president. It does not constitute an independent data controller independently determining the purposes and means of processing personal data. In this case the Committee should be treated as a body exercising so-called social oversight. Committee members, as they are appointed by the commune head, mayor or city president, should hold authorisation granted by those persons to process personal data and should provide a declaration of confidentiality regarding both personal data disclosed to them and any other information to which they will have access when reviewing applications.


