Definition
A Data Processor is a person or organisation that processes Personal Data on behalf of a Data Controller.
Human Explanation
The processor performs agreed operations on Personal Data but does not independently determine the purpose of that processing.
Why it Matters
Distinguishing controllers from processors affects the duties, instructions, contracts and Accountability applying to each party.
Conceptual Boundary
A processor acts within the controller relationship. If it independently determines purposes and essential means, its legal role may differ regardless of the contract label.
Practical Perspective
Before work starts, document the parties’ actual roles, processing scope, instructions and safeguards.