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This publication aims to clarify what role auditors play under GDPR, i.e. whether they act as data controllers or as data processors. This distinction matters as the responsibilities allocated to each role are different.
Accountancy Europe concludes that in principle, statutory auditors qualify as data controllers. For non-statutory audit services, Accountancy Europe encourages practitioners to analyse the processing of personal data on a case-by-case basis to determine whether they will be considered data controllers or data processors. Respective role and responsibilities should be stated in the engagement letter.