How do I determine if I am a Data Controller or a Data Processor?

Data Controller

You are a Data Controller if you collect, keep or process information about a living person

If your company decides what personal information is going to be kept and what use its put to then they are a Data Controller.

Data Controllers need to register with the Data Protection Commissioner


Data Processor

You are a Data Processor if you process data on behalf of a Data Controller – how ever you should remember that if you have employees you could be both a data controller and a data processor