You start by saying they are joint data controllers - the various responsibilities would then get clarified in the data sharing agreement, including that A hosts the information and provides access to B and C, etc. I don't think processing should come into it.
Donald
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 10 May 2018 09:47
To: [log in to unmask]
Subject: [data-protection] Partnerships - again
A B and C run a joint enterprise in partnership which processes personal data such that they are joint data controllers.
The data is all held, accessed and processed on A's IT systems. How do you do a data processing agreement. B and C need one, clearly, but A cannot legally contract or have a binding agreement with itself. Do we just need an agreement between B/C as controllers and A as processor in respect of their processor responsibilities? Or would you in practice do an agreement between "the partnership" and A, ignoring the fact that the partnership has no separate legal existence?
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