Who is a Data Processor?

A Data Processor processes personal data on behalf of a Data Fiduciary, under that Fiduciary's instructions. Cloud hosting providers, payroll bureaus, analytics vendors, diagnostic laboratories acting for a hospital and outsourced customer support teams are typical examples. Processors act within the scope of their contract. Critically, engaging a Processor does not transfer responsibility: the Data Fiduciary remains accountable to the Data Principal and to the Board for what its Processors do.