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 ?