External parties and transfers

Establish a joint controller arrangement

Document the allocation of responsibilities between joint controllers, the contact point, and how the essence of the arrangement reaches data subjects.

Two charities running a shared donor platform jointly decide its purpose and means, which makes them joint controllers under Article 26, with an obligation to allocate responsibilities between them and name a contact point for data subjects.

This is exercised by holding both organisations as entities, recording the joint role on the shared activity, and keeping the allocation of duties as its own agreement rather than folding it into general correspondence.

The proof is that a joint activity with no arrangement is caught as a gap, and that an individual reading the notice can find the contact point named.

Regulation

Article 26

Registers

Entity · Agreement · Processing activity · Privacy notice

The steps

1. 01Open the Entities register and create both controllers, if not already held.
2. 02Open the shared activity's Context tab and use "Link a record" to attach both entities as joint controllers.
3. 03Open the Documents register and create the joint controller arrangement, recording the allocation of duties.
4. 04Open the Linked records band on the activity and use "Link a record" to attach the arrangement.
5. 05Open the linked privacy notice and state the essence of the arrangement, including the contact point.