As an addendum to my previous post I have belatedly noticed that s6 DP Bill is probably incompatible with GDPR.It refers to "the person on whom the obligation to process the data is imposed by the enactment" which is not the same as Article 4(7) "where the purposes and means of
such processing are determined by Union or Member State law,".
Imposing an obligation to process does not mean the same thing as determining the purpose AND means -in my view. So even if there is a logical basis for ICO guidance based on s6 it is based on a flawed implementation of the definition.
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