Working with this Pharmacy Management System supplier we had the challenge of implementing compliant Data Processing Agreements with a large number of controller pharmacies as part of this project. One of the challenges was to automate the process taking into consideration that the scope of the services provided by the processor is not the same in all cases. It was important that the instructions of the pharmacy and the scope of processing was captured and formally agreed by the parties. The Data Processing Agreement was drafted to meet all the requirements of Article 28 and 32 in particular of the GDPR.
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Data Protection Programmes are all the rage these days. It’s great to see the compliance conversation moving in this direction. As a Data Protection Officer (DPO), I know the difference between working with a solid data protection programme and working with none and all.