I have been asked whether a cloud service that encrypts data so that the
staff of the service provider cannot under any circumstances encrypt it is a
Data Processor.
They are definitely 'processing', as they are 'holding' the data and
providing backup and restore facilities which are - I assume - 'operations'.
However, the definition of 'data' says that it is 'information which ...' .
If it is irretrievably encrypted, is it information? If not, it can't be
data. Or is it data because the customer can unencrypt it, even thought the
provider cannot?
Someone somewhere must have answered this already. I'm probably tying
myself in a knot unnecessarily because the common-sense answer is that of
course they are a Data Processor.
Paul Ticher
0116 273 8191
www.paulticher.com
22 Stoughton Drive North, Leicester LE5 5UB
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