GDPR Data Processor Requirements
Understanding your obligations as a data processor under GDPR and how to maintain compliance.
What is a GDPR Data Processor?
Under GDPR, a data processor is any natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data controller. Unlike data controllers who determine the purposes and means of processing, processors act under the controller's instructions.
Common examples of data processors include cloud service providers, payroll companies, email marketing platforms, IT support services, and any third-party that handles personal data for your organisation.
As a data processor, you have specific obligations under GDPR that must be met to ensure compliance. Our GDPR audit services can help you assess whether you're meeting these requirements.
Key Data Processor Obligations
Process Data Only on Documented Instructions
You may only process personal data based on documented instructions from the controller, unless required by law.
Ensure Staff Confidentiality
All personnel processing personal data must be subject to confidentiality obligations.
Implement Appropriate Security Measures
Take all measures required under Article 32 to ensure the security of personal data. Learn more about GDPR controls.Read the implement appropriate security measures guide →
Obtain Controller Approval for Sub-processors
You must have prior authorisation before engaging another processor (sub-processor).
Assist the Controller
Help the controller fulfil data subject requests and meet their GDPR obligations.
Support Audits and Inspections
Make available all information necessary to demonstrate compliance and allow for audits.Read the support audits and inspections guide →
Delete or Return Data
At the end of the processing relationship, delete or return all personal data as instructed.
Maintain Processing Records
Keep records of all categories of processing activities carried out on behalf of controllers.
The Data Processing Agreement (DPA)
GDPR requires that processing by a processor be governed by a contract or other legal act. This Data Processing Agreement must set out specific elements including the subject-matter, duration, nature and purpose of processing, types of personal data, and categories of data subjects.
A robust DPA is essential for both controllers and processors to ensure compliance. Use our compliance checklist to verify your agreements meet all GDPR requirements.
Essential DPA Elements:
- Subject-matter and duration of processing
- Nature and purpose of processing
- Type of personal data processed
- Categories of data subjects
- Obligations and rights of the controller
- Security requirements and measures
- Sub-processor engagement rules
- Data transfer provisions
- Audit rights and cooperation
- Data deletion or return provisions
Related GDPR Resources
GDPR Audit
Comprehensive audit of your data processing activities
Read the gdpr audit guideGDPR Controls
Technical and organisational measures for compliance
Read the gdpr controls guideCompliance Checklist
Verify your GDPR compliance status
Read the compliance checklist guideComply to GDPR
Practical steps to achieve compliance
Read the comply to gdpr guideNeed Help with Data Processor Compliance?
Our experts can assess your data processor obligations and help you implement the necessary controls and documentation.
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