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Therefore, the safeguards, implementd organizational or technical measures may turn out to be only apparent, and thus the security methods usd alone will not guarantee Another significant problem may be obtaining by the controller consents from its clients for further processing of personal data by other entities. The administrator’s clients will probably expect that the entities with which the administrator cooperates meet and implement all the obligations indicatd in the GDPR, which, due to the above statements, may turn out to be quite problematic.

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What about PUODO? The President of the Office for Personal Data Protection spoke in a very specific and decisive way about Latest Mailing Database concluding entrustment agreements in the case of self-employment in the Guide for employers issud in October 2018. PUODO indicatd then how it is acceptable for persons cooperating on the basis of concludd civil law agreements to access to personal data containd in the administrator’s resources. PUODO clearly statd that obtaining the possibility of processing personal data at the request of the administrator should be basd on authorization.

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If only the self-employd person uses the administrator’s resources and organizational solutions and closely cooperates with the Email Data administrator in accordance with his instructions: “The processor and any person acting under the authority of the controller or the processor, having access to personal data, process them only on instructions from the controller, unless other provisions provide for an exception. If the employee has an employment relationship with the employer, he or she may process personal data administerd by the employer on the basis of the authorization grantd.

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