WORK CONSULTANTS. When they are responsible and when data controllers: clarifications of the Privacy Guarantor.

The job consultants are "Holders" when they process, in full autonomy and independence, the data of their employees or of their customers when they are natural persons, such as freelancers, promptly determining the purposes and means of the processing.

On the other hand, I am "Responsible" when they process the data of their customers' employees on the basis of the assignment received, which also contains instructions on the treatments to be carried out. This is the case, for example, of consultants who, on behalf of employers, take care of the preparation of pay slips, practices relating to hiring and termination of employment, or social security and welfare ones, treating a plurality of personal data, including sensitive ones , of workers.

To this link the long answer to the question posed to the Privacy Guarantor by the National Council of Labor Consultants.