Art.26 Joint controllers
Where two or more controllers jointly determine the purposes and means of processing, determine their respective responsibilities for compliance in a transparent manner by an arrangement between them, unless those respon
5
artefacts
0
held by a system
2
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- The joint controllership assessment identifying every relationship where purposes and means are jointly determined · Document repository
- Evidence the allocation reflects the real roles, such as which party holds the data and which faces the data subject · Identity provider / directory
governing documentDocuments that govern the control
- The Article 26 arrangement for each, allocating responsibility for rights handling, transparency, security and breach response · Document repository
- The essence of the arrangement as published or otherwise made available to data subjects · Document repository
- The operating process showing a rights request is honoured whichever joint controller receives it · Document repository
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- A controller to processor agreement used where the relationship is in substance joint controllership
- An arrangement signed but its essence never made available to data subjects, which is a separate obligation
- Rights requests passed back and forth between joint controllers, when the data subject may exercise them against either
- The allocation written to suit the commercial balance of power rather than the actual roles towards data subjects
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetArt.25 Data protection by design and by default · Art.27 Representatives of controllers or processors not established in the Union