What is a processor under GDPR?
A processor processes personal data on behalf of someone else (the controller). Hosting provider, email service, SaaS supplier — processor with own GDPR obligations.
GDPR Art. 4(8) defines processor as "a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller". Practical: parties that process data on your behalf — not for their own purposes. Examples: hosting provider (TransIP, Hetzner) hosting your customer data, email service (Mailchimp, MailerLite), payroll provider (Visma, Loket), SaaS CRM (HubSpot, Salesforce), cloud storage (Google Workspace, Microsoft 365), Stripe + Mollie for payments. NOT a processor: parties processing data for their own purposes — e.g. Dutch tax authority receiving your employee data (separate controller), Google Analytics in standard mode (Google sets its own purposes too). Since Schrems II + recent EDPB guidelines this distinction is sharp. Data Processing Agreement (DPA) required (Art. 28(3)) — written contract specifying instructions, security measures, sub-processors, GDPR-rights assistance, breach procedure. Working with a processor without a DPA = GDPR breach. Processor's own obligations: security measures, only act on instructions, report breaches to controller, assist with DPIAs, return/delete data at contract end. Liability: processors can also be fined (separately) — fines 2023-2025 against SaaS providers for missing DPAs or unreported sub-processors.
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