UK GDPR controller-processor contracts: Article 28 duties, sub-processing, negotiation, enforcement and compliance across supply chains (including Data (Use and Access) Act 2025 changes)

Published by a LexisNexis Information Law expert

Practice notes

This Practice Note sets out the requirements of the United Kingdom General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR), where a processor handles personal data for a controller in a commercial setting. It proceeds on the basis that readers are already familiar with core data protection concepts, terminology, and the functions of key regulators. For an initial overview of data protection law, consult the ‘key principles and concepts’ tab in the UK Data Protection toolkit, which is a recommended starting point for research. For a higher-level primer on this topic and connected matters, see: Data sharing and transactions—overview. This Practice Note also sits within the Data protection negotiation guide—controller: processor—collection, which practitioners drafting or negotiating data protection clauses between a controller and a processor may find helpful.

In brief

UK data protection legislation aims to ensure information about living people (within the scope of ‘personal data’) is treated fairly and responsibly. To achieve this, the UK GDPR places extensive duties on those ‘processing’ personal data (and on controllers responsible for such processing). ‘Processing’ is interpreted broadly to cover most activities involving data, including storing, erasing, collecting, disclosing together with other comparable operations on such information and records too...

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Web page updated on 22/05/2026

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