Thanks for the explanation Adrian..
I see what you mean - this issue comes up a lot now days in different communities. What if ….
For Fiduciary Role - this Master Controller works very well IMO - using the word agent (which is the word of the broker) I think doesn’t help - but - indicting that the liability and responsibility for controlling personal data on a data subjects behalf, is placed with a controller (on top of their existing legal obligations) I think makes a lot of sense - and it basically uses a legal term that is recognised internationally for privacy. Controller ..
In application, it seems that with this fiduciary legal distinction then the Master Controller’s - Agent or Operator, (would have that fiduciary role) .
How would define this enhanced obligation or role for a personal data controller?
Master Controller : Has the additional fiduciary role of controller personal data, making personal data decisions on behalf of a data subject or group of data subjects, and is designated a Master (Data or PII) Controller designating this fiduciary role, which should be linked to the fiduciary governance framework/agreement/code of conduct etc.
- Mark