Jurisdiction(s):
United Kingdom
Key definition
Data definition

What does Data mean? In legal practice, data describes information recorded in any form—especially electronically stored information (ESI)—organised or capable of being organised for a particular purpose, and capable of being processed or transmitted. It covers structured and unstructured material such as database entries, spreadsheets, emails and messaging content, documents, images, audio/video, metadata, system logs, backups and cloud-stored content. Data is not defined in the Civil Procedure Rules of England and Wales (nor generally in equivalent court rules), which instead use the broad concept of a document as anything in which information is recorded, encompassing electronic data and metadata. Statutes define data contextually: UK GDPR...

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UK GDPR representative appointment and notification clauses for controller–processor (supplier–customer) agreements — pro-controller and pro-processor options

Precedents
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Note

These provisions are prepared on the basis that the applicable contract is a business-to-business arrangement, with the supplier acting as processor for a customer in the role of controller, in relation to the processing of personal data governed by the United Kingdom General Data Protection Regulation (UK GDPR), Assimilated Regulation (EU) 2016/679. The terms ‘supplier’ and ‘customer’ (in place of ‘processor’ and ‘controller’) are used to simplify incorporation into commercial contracts. The drafting also relies on the additional defined terms ‘Agreement’, ‘Business Day’, ‘Customer’, ‘Data Protection Laws’, ‘Data Subject’, ‘GDPR’ and ‘Supplier’, which are assumed to be defined appropriately elsewhere in the relevant agreement. It is further assumed that ‘GDPR’ refers to UK GDPR and that ‘Data Protection Laws’ includes UK GDPR. These provisions can also be adapted for circumstances where the EU General Data Protection Regulation (EU GDPR), Regulation (EU) 2016/679, applies...

1 Definition (to be incorporated into relevant part of the agreement)

1.1 representative

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Constantinos Papadopoulos
Constantinos Papadopoulos

I currently work as a CIPP/E-qualified data protection paralegal within DWF’s Data Protection Extend and Accelerate team. In this role, I support clients with a wide range of data protection and privacy compliance matters, drawing on both legal expertise and practical experience.Prior to joining DWF, I worked at a silver circle law firm in the UK where I gained valuable exposure to complex regulatory and legal issues. My academic background includes a Bachelor of Laws (LLB) from Scotland, two postgraduate diplomas in law, and a Master’s degree, all of which have equipped me with a strong foundation in legal reasoning and cross-border regulatory frameworks.I am also a qualified lawyer in Cyprus, having completed my legal training at one of the Big Four accounting firms and then went on to work at a few reputable national law firms. Separately, I held two...

Tughan Thuraisingam
Tughan Thuraisingam

Tughan has extensive experience in supporting clients with large-scale privacy compliance programmes and post-acquisition privacy alignment projects. He enjoys working closely with innovation and technology teams to embed privacy into the operations of a client's business.  Prior to DWF, Tughan worked in the legal services business in a Big 4 accountancy firm. He spent over two years on secondment to one of the world's largest global payments technology companies. Through his in-house experience, Tughan has developed substantial expertise in providing pragmatic and commercially focused solutions to the more complex issues faced by clients in this area. Tughan is part of the Data Protection Finance Group ('DPFG') leadership team. The DPFG is a communication network of over 400 lawyers and privacy professionals across the financial services sector....

Web page updated on 22/05/2026

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