A company adopts a SaaS payroll platform. The provider processes employee personal data strictly on the company's documented instructions and does not decide the purposes of processing. Under data protection principles, how are the two parties best classified?
- ABoth the company and the SaaS provider are joint controllers because they share access to the same personal data.
- BThe company is the data controller and the SaaS provider is the data processor. Correct
- CThe SaaS provider is the data controller and the company is the data processor acting on its behalf.
- DThe SaaS provider is a sub-processor and the company is an unrelated third party to the processing.
Why A is wrong: Shared access alone does not create joint control; joint controllers must together determine the purposes and means, which the provider here does not.
Why B is correct: Correct. The company decides the purposes and means, making it the controller, while the provider acting only on documented instructions is the processor.
Why C is wrong: This reverses the roles; the party that determines purposes is the controller, and here that is the customer, not the provider.
Why D is wrong: A sub-processor is engaged by a processor, and the customer is a party to the processing as controller, so neither label fits this direct relationship.