A recent ruling by Belgium's data protection authority (DPA) has emphasised the need for having data processing agreements in place to regulate data processing arrangements from their inception. The DPA stated that inserting a data processing agreement into a contract and providing for it to apply retrospectively doesn't remedy its absence under the EU General Data Protection Regulation (GDPR). The case involved a man who complained about the lack of a data processing agreement being put in place between a municipality in Belgium and a third-party computer engineering company the municipality had engaged. The case provides a valuable lesson to all organisations subject to either the EU or UK GDPR.
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