Chris
The analysis in my referenced blog would seem to suggest yes an STP should register - although I would like to think about it some more.
Having said that, the fact that processing without registration will not now be a criminal offence gives some leeway providing all the partners do what they need to do. You could wait to see if ICO issues an enforcement notice against the STP ...
One thing is clear - the partners need to determine clearly their responsibilities - Art 26. Possibly that will point to an answer. The decision making processes in some joint arrangements may make the STP a controller, in others perhaps not. Certainly if you are doing things like entering into contracts in the name of the STP it begins to look rather like a controller.
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