In the past, order processing was often assumed where the supervisory authorities now speak of shared responsibility. You should therefore check whether some of your data processing contracts do not need to be converted and whether contracts on joint responsibility should be concluded instead.
Specifically, this can be the case with data processing at corporations, e.g. B. in the case of personnel administration or payroll taking over by one company for the other. Where this was previously seen as order processing, we can now assume joint responsibility.
It should also be noted that in the case of joint responsibility according to Art. 26 Paragraph 2 GDPR, the essential contract content must be made available to the parties concerned. This obligation exists in addition to the information obligations according to Art. 13 and 14 GDPR.
Please do not hesitate to contact us if you would like support. We can help you check whether there is shared responsibility in your particular case. We would also be happy to advise you on drawing up the contracts and on fulfilling the information obligation in accordance with Art. 26 Paragraph 2 GDPR. Call us on 08505 919 27-0 or fill out our contact form.