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Governance, Risk, Audit & Privacy · Intermediate

Joint Controllers

Two or more controllers that jointly determine the purposes and means of processing.

Definition

Under GDPR Article 26 joint controllers must transparently determine their respective responsibilities in an arrangement, and data subjects can exercise rights against each. Court rulings such as Fashion ID and Wirtschaftsakademie found website operators and social networks to be joint controllers in some cases.

Example

A co-branded marketing campaign where two companies decide together what data to collect makes them joint controllers.

Exam tip

Joint controllers need an Article 26 arrangement, not an Article 28 processor contract.

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