Normally I'd agree, but then I read the Facebook fan page judgment so perhaps there is a small argument for B being controller in very specific circumstances?
https://panopticonblog.com/2018/06/05/the-facebook-fan-page-judgment-joint-data-controllers-cookies-and-targeted-advertising/
Although in Phil's situation B is probably wrong :-)
Victoria Blyth
Information Strategy Manager (Interim Data Protection Officer)
Information Management Team
London Borough of Barnet, North London Business Park, Oakleigh Road South, London N11 1NP
Tel: 020 8359 2015
please consider the environment - do you really need to print this email?
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Peter Dinsdale
Sent: 30 July 2018 11:25
To: [log in to unmask]
Subject: Re: [data-protection] Processor for own data - am I missing something
Organisation B has definitely gone mad!
If the data wasn't anonymised, it would be a controller to controller transfer. The anonymisation processing doesn't make this into a processor-controller arrangement in my opinion.
Regards,
Peter
Peter Dinsdale
Data Protection Consultant
Perfect Image /
T: 0191 238 0111
www.perfect-image.co.uk
Follow us on Twitter http://twitter.com/perfectimage
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Phil Bradshaw
Sent: 30 July 2018 11:17
To: [log in to unmask]
Subject: [data-protection] Processor for own data - am I missing something
Organisation A holds a personal data set. It agrees to submit on a regular basis an anonymised extract from this set to organisation B in accordance with organisation B's specified requirements.
Organisation B wants organisation A to sign a processing agreement on the basis that it is processing the data (anonymising it) on B's instructions.
Have I gone mad (point blank refusal to sign but happy to submit the data) or has organisation B ?
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