PFRON commissioned PCPR to implement a programme. PCPR collects and stores data that is also processed in the SOW programme operated by PFRON. Who is the data controller?

ANSWER

In the situation described, it is necessary to establish which of the entities decides on the purposes and means of processing data. If both entities jointly decide on the purposes and means of processing, a joint controllership agreement on personal data should be concluded.

With regard to the question described, without a detailed analysis of the programme details and the roles of both entities, it is not possible to indicate who will be the data controller.