personuppgiftsbiträden

Personuppgiftsbiträde is a natural or legal person, public authority, agency or other body that processes personal data on behalf of a data controller and follows its documented instructions. The processor does not determine the purposes or means of processing; that remains with the controller. The term is used within the GDPR framework and is commonly applied in Sweden as a formal processing role.

Key obligations of a personuppgiftsbiträde include processing personal data only on documented instructions from the controller, maintaining appropriate security measures, and ensuring confidentiality among personnel. The processor must assist the controller in fulfilling data subject rights requests, supporting data protection impact assessments when needed, and notifying the controller of data breaches without undue delay. They are also expected to keep records of processing activities and cooperate with supervisory authorities when required.

A processor may engage sub-processors only with the controller’s prior written authorization and must impose the same data protection obligations on those sub-processors. If sub-processing is used, the processor remains responsible for the acts of the sub-processor and must ensure that safeguards are in place to protect personal data. Transfers of personal data to third countries require appropriate safeguards in line with GDPR requirements, typically outlined in a data processing agreement.

A data processing agreement (DPA) or similar contract is essential to define roles, processing purposes, security measures, breach procedures, and the duties of both parties. While the controller bears primary responsibility for compliance, the processor has a central role in implementing and maintaining data protection practices throughout processing activities. Examples of processors include cloud providers, payroll services, IT support, and CRM or HR systems vendors.