The Personal Data Flow from the Data Subject via the Controller to a (sub) Processor up to cleansing/deleting. Having an overview of Personal Data at hand is paramount. Check for practical solutions: technical and/or organizational measures. The Flow in a picture:
from Data Subject | what | action by |
DPIA / GDPR by design | PNO | |
Privacy Statement | PNO | |
Cookie Policy | PNO | |
General Terms & Conditions | PNO | |
Contract | PNO / Client | |
Shared responsibility | PNO / Client | |
Consortium Agreement | Client / PNO | |
Processing Agreement | Client | |
Consent | Client | |
via Controller | ||
Processing Agreement | PNO | |
Audit | PNO / Processor | |
to Processor | ||
Processing Agreement | PNO | |
Audit | PNO / Sub Processor | |
to Sub Processor | ||
and Cleansing | Anonymise Data | PNO |
finish Cleaning up | Deletion Data | PNO |