In a situation where the administrator also uses civil law forms of employment (including self-employment), where such persons as a result, when processing personal data, use the administrator’s means and organizational solutions (e.g. systems, rooms), and moreover, they do so at the request of the administrator , authorization should also be considerd as a condition for allowing data processing. The controller, in accordance with the accountability principle.

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Should be able to prove the fact of granting authorization to process data. In such situations, as a rule, data processing is Latest Mailing Database not entrustd.” It follows from the above that if the relevant conditions are met, it is possible to process personal data on the basis of an authorization without the ned to conclude a personal data processing agreement with a self-employd person. Importantly, PUODO emphasizd that in order to meet all obligations, it is necessary to implement the accountability principle, so that at the time of any checks or audits, the controller can demonstrate that the basis for the processing order.

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Him is appropriate and adequate in a particular case. Summary Each case of granting access to personal data by the controller should be considerd on a strictly individual basis. Due to the fact that self-employd people often undertake orders Email Lead for other entities, use their own resources, own equipment and apply individual forms of security, it may be necessary to conclude an agreement to entrust the processing of personal data. However, the controller must take into account the consequences of starting cooperation with such an entity, even in the context of obtaining consents from its clients for further data processing by co-workers.