- The GDPR and complex supply chains
- What other controller/processor scenarios are practitioners facing which are not presently addressed by the GDPR or guidance from supervisory authorities?
- How are arrangements between customers, and third parties processing personal data on their behalf, being approached (and changing) under the new GDPR regime?
- How are customers approaching scenarios involving situations in which a customer contracts with a contractor that engages a sub-processor that will itself appoint a sub-processor (including situations where no personal data will be transferred to or processed by the prime contractor)?
Information Law analysis: The meeting point of transnational legislation such as the General Data Protection Regulation, Regulation (EU) 2016/679 (GDPR) and transnational systems such as supply chains will, for some time to come, throw up challenges that companies must stay abreast of. Miriam Everett, of Herbert Smith Freehills, assesses what lies ahead in complex supply chain management, including further issues that GDPR may yet augur.
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