I recently did a full analysis for an OHS which was effectively a partnership of several NHS Trusts, hosted by one of them, provided OHS to the partners but also to external third parties. About as complex as it gets ...
Basic conclusion = joint data controllers but with a need to carefully allocate responsibilities as per GDPR Art 26 in the partnership and hosting agreements. Happy to send a copy but will be next Tuesday as I am enjoying some time in the sun.
I'm not sure the processor for records works because of confidentiality. For example when providing an OHS to an employer the OHS would not expect to hand back the records on termination to the employer as that would breach confidentiality but can transfer with consent to a replacement OHS (if any) or retain the records if the employer stops providing an OHS service.
All archives of messages are stored permanently and are
available to the world wide web community at large at
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)