What is GDPR Article 29 and Why Does it Matter?
GDPR Article 29 requires organisations to only process data on instruction, unless required to do otherwise by a legal authority.
GDPR Article 29 Legal Text
EU GDPR Version
Processing under the authority of the controller or processor
The processor and any person acting under the authority of the controller or of the processor, who has access to personal data, shall not process those data except on instructions from the controller, unless required to do so by Union or Member State law.
UK GDPR Version
Processing under the authority of the controller or processor
The processor and any person acting under the authority of the controller or of the processor, who has access to personal data, shall not process those data except on instructions from the controller, unless required to do so under domestic law.

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ISO 27701 Clause 8.2.2 (Organization’s Purposes) and EU GDPR Article 29
From the outset, PII should only ever be processed in accordance with the customer’s instructions.
Contracts should include SLAs relating to mutual objectives, and any associated time scales that they need to be completed within.
Organisations should acknowledge their right to choose the distinct methods that are used to process PII, that lawfully achieve what the customer is looking for, but without the need to obtain granular permissions on how the organisation goes about it on a technical level.
Index of Linked EU GDPR Articles and ISO 27701 Clauses
GDPR Article | ISO 27701 Clause | ISO 27701 Supporting Clauses |
---|---|---|
EU GDPR Article 29 | ISO 27701 8.2.2 | None |
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A breach of GDPR can result in significant fines, making it one of the world’s toughest privacy and security regulations. As a result, it implies that organisations must protect personal data to a ‘reasonable’ extent.
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