A data processor has asked for the following clause in a contract (I represent controller):
The Controller agrees at the Processor's request to provide information notices (for the purposes of Articles 13 and 14 of GDPR) prepared by or on behalf of the Processor, or notifications about such information notices, to Data Subjects who are subjects of the Controller or staff engaged by the Controller as employees or contractors.
Would you accept this?
I fail to see the point as there is no requirement as such for the processor to give a PN to our subjects - that is entirely our responsibility. Further it raises the possibility of conflict with the requirement that the processor act at all time on our instructions when handling the data. E.g. processor requires us to give a notice saying he will keep the data for two years when as controller I stipulate 3 months.
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