AIRiskAware
AI Governance Glossary
Governance Concept

What Is Data Processor?

Data Processor is an entity that processes personal data on behalf of, and on the instructions of, a data controller.

Definition

Data Processoran entity that processes personal data on behalf of, and on the instructions of, a data controller.

A processor acts for the controller and cannot use the data for its own purposes. The relationship must be governed by a contract setting out security and confidentiality duties (GDPR Article 28). Many AI vendors are processors for their customers — but if a vendor starts using customer data to train its own models, it may have become a controller, with all the attendant duties.

Source: GDPR, Articles 4(8) and 28

Plain-language explanation

A processor acts for the controller and cannot use the data for its own purposes. The relationship must be governed by a contract setting out security and confidentiality duties (GDPR Article 28). Many AI vendors are processors for their customers — but if a vendor starts using customer data to train its own models, it may have become a controller, with all the attendant duties.

Primary source: GDPR, Articles 4(8) and 28

Related terms

Data Controller Third-Party AI Risk Purpose Limitation

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