Am I over thinking this? My background in in IG local gov’t sometimes the commercial world of parent company and subsidiaries etc. bamboozles me.
I’m interested in the views of those DPOs or DP staff which act for more than one company, in particular where the DPO is employed by the parent company and is required to provide advice and undertake practical DP tasks for subsidiaries.
What issues crop up, if any, and how have you resolved them?
Scenario – IG/DP staff are employed by the parent company. There are a number of subsidiaries. Each company is a separately registered data controller. The DP staff are required to give advice and undertake practical tasks for all the companies, sort of a group company arrangement. On some occasions both parent company and subsidiaries procure each other’s services, generally as data controller and processor relationship but on the odd occasion they could both be controllers.
Is it necessary to put in place written agreements between the parent company and the subsidiaries in order to provide them with DP advice and undertake DP tasks? If so should that be a contract or does an SLA suffice? (In the LA world providing DP advice for schools or wholly owned companies we put in place SLAs).
How does the above apply when services are procured from each other and the DP officer is acting for both parties. Is there a conflict of interest? Is it possible to provide advice independently and in the best interests of each party? What if there is a breach situation and you are advising both companies and are the contact point for the supervisory authority for both parties.
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