Accountor's Roles

Accountor plays different roles in the processing of personal data depending on the context of processing.

Accountor As a Service Provider

Data processor is a party processing personal data on behalf of other entity. As a service provider, we usually process personal data on behalf of our customers in the role of a data processor, e.g. when providing

• payroll services
• accounting services
• hosted IT-services

We also provide software services to our customers, which are used for the processing of data, yet the customers install and operate the software themselves. In such case, Accountor is not a processor since it does not have any access to personal data processed therein.

As regards both cases, Accountor does not have independent rights in regard to personal data and we must follow instructions agreed with our customers. Customers have decision-making powers on the means and the purposes of the processing and, thus, they are in the role of a data controller. Consequently, the customers are responsible for the lawfulness of the processing.

However, when providing services Accountor does not only act as a data processor but also as a data controller. In such cases we

• manage and control our relationship with customers
• administer services provided
• process personal data of our customer’s representatives, decision makers and other contact persons

Thus, we are responsible for the processing conducted in our role as a data controller.

Accountor As an Employer

Naturally, we process personal data of our employees in the employment relation. In such case, Accountor is a data controller who is responsible for the lawfulness of the processing no matter whether the processing is carried out internally or externally by the data processor. The same applies to leased employees.

In addition, Accountor may acquire some services for its employees that are closely related to the employment relation and personal data are processed therein.

A practical example of such situation:

• Accountor may acquire occupational health care services. In regard to personal data processed in that context Accountor is not a data controller nor a data processor. Company just takes care of the expenses as part of the employment relation but does not have the right to control or decide on the personal data.

Consequently, the health care provider is the data controller.