What is a data processor?

In today’s data-driven economy, the role of the Data Processor has moved from the background to the spotlight — particularly under the EU’s General Data Protection Regulation (GDPR). As organisations increasingly outsource services that involve personal data, such as payroll or customer data management - the Data Processor has become a critical link in the chain of accountability. Unlike the Data Controller, who decides the ‘why’ and ‘how’ of processing, the Data Processor acts on their behalf. But this is no passive role: under GDPR, processors have clear responsibilities and can face direct consequences for non-compliance.

Understanding the Data Processor’s obligations is essential not just for legal compliance, but for building trust in an era of rising scrutiny over data privacy. For instance, when a data subject - the individual that the data is about - exercises rights like data portability — the right to move their personal data from one provider to another — the processor’s systems and practices will determine how smooth, secure, and robust that experience is. As privacy expectations evolve and digital services grow more complex, getting this right isn’t just a regulatory box-tick - it’s a strategic advantage.

In later sections, we’ll explore how processors fit into the broader privacy ecosystem and what smart organisations are doing to stay ahead.