We are working with an independent financial advisor who will be acting as a broker for our death in service benefits. Am I right in thinking that in this capacity they would be acting as our data processor?
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The role of controller or processor is determined by the facts of the case. In the past (2014 guidance) the ICO held most providers, acting on the instructions of a controller, to be data processors. In subsequent updates to the data controller – data processor guidance, the ICO revised their view in respect of professional service providers. So, in your example, a financial advisor would now be regarded as a data controller. Alas, we have lost the distinction between ‘joint-data controller’ and ‘data controller in-common’, and whilst you may limit the scope of processing that the financial advisor, carries out for you, they remain subject to external laws and standards and are still an separate data controller.