Personal Data Protection Act, No. 9 of 2022
51
“processing” means, any operation performed on
personal data including but not limited to
collection, storage, preservation, alteration,
retrieval, disclosure, transmission, making
available, erasure, destruction of,
consultation, alignment, combination, or the
carrying out of logical or arithmetical
operations on personal data;
“processor” means, a natural or legal person, public
authority or other entity established by or
under any written law, which processes
personal data on behalf of the controller;
for the avoidance of doubt, a processor shall
be a separate entity or person from the
controller and not a person subject to any
hierarchical control of the controller and
excludes processing that is done internally
such as one department processing for another,
or an employee processing data on behalf of
their employer;
Illustration: Hospital A, employs a data
scientist as an employee to manage its
analysis of patient records. The Hospital has
decided to store its patient records on a thirdparty local cloud platform hosted by
Company B. Hospital A is the controller, and
the Company B is the processor where
management of patient records are concerned.
The data scientist of the hospital is only an
employee of the controller and not a
processor.
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