Absolutely.
Many ISA's will be controller-controller.
Label's are irrelevant The most important thing is to be clear whether it is controller-processor. If so then it must be fully Art 28 compliant and that is fairly rigorous and does not really need much discussion and leaves little room for disagreement.
If controller - controller it can be any old waffle you mutually agree on to meet the first sentence of Art 26. that can be anything from a 50 page ISA - they still exist or a couple of paragraphs both agreeing to comply with GDPR and provide mutual assistance / due diligence.
The real fun comes when you cannot agree which it is and have to cover both bases as one of you will be wrong ... and you hopefully never have to find out for sure
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|