The role follows the facts
The controller determines the purposes and essential means of processing. A processor handles personal data on the controller's behalf and according to documented instructions. The parties cannot simply choose whichever label is more convenient.
The typical WhyBecause relationship
For customer meeting transcripts, the customer organization will generally decide why the transcript is processed, who may access it and how it is used. WhyBecause generally acts as a processor for that service activity. WhyBecause remains a controller for separate purposes such as account administration, billing, security and its own legal obligations.
What must be documented
- Purpose, nature and duration of processing.
- Categories of personal data and people concerned.
- Security measures and subprocessors.
- Assistance with rights, incidents, deletion and audits.
Official sources
Use the authoritative texts below when making legal or compliance decisions.
This resource provides general product and operational information. It is not legal advice. Your organization remains responsible for assessing its specific use, lawful basis and obligations.