Short paper no.16 – Jointly responsible data processors
The Data Protection Conference has also now published a Short paper on jointly responsible data processors (version 2018-03-19).
The Data Protection Conference in this short paper discusses, among other, the lack of privilege and separation of this special constellation from e.g. order processing; it also lists special obligations of jointly responsible entities and discusses application cases.
This is the 8th publication of short papers on the GDPR, starting with the first publication of the first three short papers early in July 2017 (for the other Blog articles on the publication of short papers click here, here, here, here, here, and here).
This short paper is also (as described above) subject to future –possibly different –interpretation of the European Data Protection Board.
Author: Frank Spaeing