Can an employee be a processor? Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR) was implemented in the UK by the Data Protection Act 2018 (DPA 2018). DPA 2018 repealed the Data Protection Act 1998 (DPA 1998), which implemented the predecessor to GDPR, Directive 95/46/EC, the Data Protection Directive. Under Regulation (EU) 2016/679, GDPR: • ‘processor’ is defined as’ a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller’, and • ‘controller’ means ‘the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law’ For further information, see Practice Notes: