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GDPR roles: when to use a processor agreement and when it’s unnecessary
“Better safe than sorry,” “better too many than too few,” and “fire is worse.” All true, but still not a reason to start signing agreements unnecessarily. Yet this is exactly what I now see happening on a large scale. Organizations that share data are massively sending each other data processing agreements. And not just to each other: their own employees, the Tax Authority, and the company doctor are also being dragged into it. Please don’t forget to fill in annexes 1 through 4 yourself, in the name of the GDPR. No processing without a processing agreement. Or is there? Let’s start at the beginning.