Who are the key stakeholders?
Data processor means any person who processes the personal data for and on behalf of the data fiduciary. Processor will include government, all private and public entities and individuals. This is similar to “processor” under EU General Data Protection Regulation. For example, in the prior illustration, Google in providing analytics services to the travel company will act as a data processor.
The processor must comply with fair processing principles, retain the confidentiality of personal data, and process strictly in accordance with the data fiduciary’s instructions. A data processor can be engaged through a valid contract, and where the processor wants to involve a sub-processor, prior consent must be obtained from the fiduciary. Liability and penalty can be imposed on a data processor if it breaches processor-specific obligations under the contract or any specific order issued by the Data Protection Authority.
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