Would that be different if the design of the assessment and scoring was already set out, but the resource completing it was the supplier?
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Tony Sheppard
Head of Services
GDPR in Schools
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Phil Bradshaw
Sent: 04 April 2019 15:55
To: [log in to unmask]
Subject: Re: [data-protection] Joint Controller or Separate Controllers?
I disagree with the two previous comments.
I would categorise this as controller - controller. In general when someone is providing a professional service and exercising judgement that is controller activity. Is it really different in principle from e.g. a GP getting a report from a cardiologist - yes I know there are differences as a workspace assessment is more specifically defined.
If I was such a supplier, at risk of being sued by someone who suffered injury if my assessment was alleged to be negligent, I certainly would not want to regard myself as a processor, when the customer could on a whim insist I destroy all my records. I wouldn't be happy. My insurer would be less happy ...
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