Bill - a much more succinct way of putting what I just posted to the list!
I agree.
R
Renzo Marchini
Counsel
Dechert LLP
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-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Bill Dunn
Sent: 17 September 2012 09:36
To: [log in to unmask]
Subject: Re: [data-protection] Outsourcing
Hi, having a Monday morning...
Is it correct to say that a data controller must meet a condition set down in Schedule 2 and 3 (as appropriate) before it can use a data processor? As far as I am aware the personal data is still being processed by the data controller in line with the purposes set down in its Notification/privacy notices? The information cannot be being "disclosed" to the data procesor as the data controller remians fully in control of the use of the information and the data provcessor cannot use the personal data in any way without the consent of the data controller.
Of course if the data processor can use the information for its own purposes, it is a data controller in its own right. However that would be data sharing rather than outsorcing which generally is taking on a data processor? I may be missing something very obvious - but it is still quite early in a Monday morning for me...
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