Data Controller in GDPR: Defining responsibility in data processing

A data controller is an individual, organization, or other entity that determines the purposes and means of processing personal data. Under the General Data Protection Regulation (GDPR), controllers bear the primary responsibility for ensuring that data is collected, stored, and used lawfully.

By setting the why and how of data processing, controllers play a crucial role in privacy compliance and must adhere to GDPR’s transparency, security, and accountability principles.

What does a data controller do?

A controller is responsible for making key decisions about:

  • Purpose – Why personal data is being processed.
  • Means – What methods, systems, and technologies are used for processing.
  • Lawfulness – Ensuring there is a valid legal basis for processing data.
  • Data subject rights – Providing individuals with access, rectification, and deletion options.
  • Security measures – Protecting personal data from unauthorized access or breaches.

Key responsibilities of a data controller

  • Determining the lawful basis for processing personal data.
  • Providing clear privacy notices to data subjects.
  • Ensuring compliance with GDPR principles.
  • Supervising processors that handle data on their behalf.
  • Maintaining records of data processing activities (ROPA).

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Controller vs. processor: What is the difference?

Under GDPR, controllers and processors have distinct roles:

  • A controller decides why and how personal data is processed.
  • A processor handles personal data on behalf of a controller and follows their instructions.

1. When is an entity a data controller?

An entity is a controller if it:

  • Decides why and how personal data is processed.
  • Has direct interaction with data subjects (e.g., customers, employees).
  • Establishes data retention and security policies.

2. What are a controller’s obligations under GDPR?

Controllers must:

  • Demonstrate compliance through policies and documentation.
  • Respond to data subject requests, such as access and erasure requests.
  • Ensure data security by implementing technical and organizational measures.

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Why understanding the role of a controller is crucial

Ensuring compliance as a data controller helps organizations:

  • Avoid GDPR fines by fulfilling legal obligations.
  • Protect personal data through proper governance.
  • Build customer trust by demonstrating accountability.
  • Improve efficiency in data processing and management.

By taking proactive steps to meet GDPR requirements, controllers can ensure secure, lawful, and ethical data processing while minimizing risks.