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New ICO self-assessment for GDPR

Question 4 - "Is your organisation responsible for deciding how the information is processed?"

Now that the questionnaire has been updated, my wife (a payroll agent who has not previously registered with the ICO) and I (an accountant who has) have re-visited it.

We think that as she just processes payroll at the instruction of employers using their data and a well-defined set of rules, she can answer No to this question. Does the community agee and if not why not?

I suppose that the work of accountants is more varied and complex, but assuming Payroll agents can answer No, where is the dividing line? After all, we accountants receive data from our clients with the purpose of preparing accounts and Tax Returns according to various sets of rules. Are we deciding how to process data ?

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19th Jun 2018 11:17

I cannot understand why you think your wife should not be registered with the ICO. She is surely in the same position as any accountant.

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By Selaen
20th Jun 2018 10:57

Does she store the data? As that doesn't have specific rules set in law, surely she is deciding on how the information is processed and thus liable to register?

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23rd Jun 2018 11:42

For £35 pa is it worth the risk? Get her to register - from what you have said your wife holds data on a computer or the like and must be registered.

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