The Data Processor within the GDPR and the Italian Data Protection Code following the amendments introduced by L. 167/2017: external or internal data processors?
In this special essay Prof. Avv. Alessandro del Ninno comments the new law rules about data processors as set forth in the GDPR no. 679/2016, also in light of the execution rules recently enacted and introduced by art. 29 of the Italian Data Protection Code as amended by the Law no. 167/2017.
The essay proposes a reasoned lecture of the data processor as role and figure, clarifying if data processors must be exclusively external ones or if internal data processors can be provided within the data controllers' organizations, after the GDPR.
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