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The GDPR/DPA only mandate a contract when you engage a data processor to carry out work processing personal data on your instructions. This does not appear to be that type
of relationship. Here you appear to be exchanging personal and business data for the purpose of setting up a series of sales contracts between you and other companies.
Obviously you would need to set out in your privacy notices what you are doing with this personal data and I guess if you wanted to highlight that in your T&Cs that would be
a way of getting the information across. I don’t think anything else is required.
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]]
On Behalf Of Gillian Galbraith
Sent: 18 October 2018 13:03
To: [log in to unmask]
Subject: [data-protection] Contracts
Hi,
My query is regarding contracts;
We place a number of orders with various companies, initially we require then to complete a purchase ledger set up form (includes names, company bank details) and this information is then input into Sage. They subsequently send us a new
customer credit account application where we have to provide our banking details, contact name and two trade references. Do we need to have contract in place for each company or would our terms & conditions suffice as long as we had a section including data
protection?
Regards
Gillian
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