Do Joint Controllers Need A Data Processing Agreement

The controllers may have a very close relationship, which means that they share all the purposes and means of the processing activities, or a more distant relationship in which they only partially share the purposes. Nevertheless, responsibilities must be defined and assigned. The case law of the ECJ shows that the threshold for the existence of shared responsibility is low and that it is not necessary for the parties to share responsibility equally or for both parties to have access to the data in question. On the other hand, researchers can enter into a contract with a company to send surveys to the people concerned or analyze certain interview results. This would be a treatment on behalf of the researchers, although both parties contribute to a project. .

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