When do I need a commissioned processing agreement (GDPR)?

We check which data you send us, not which products you select:

Pure postal addresses (street, house number, postcode, city and country) are not personal data and do not require an order processing agreement. The same applies to the VAT identification number.

However, as soon as a name, an e-mail or a telephone number is transmitted to us, we require an agreement.

What is clear: Adresslabor is the contractor of a commissioned processing. You as the client outsource the verification of your data to an external service provider.

Now it depends on whether you send us personal data for verification or only anonymised data. In the first case, we need a commissioned processing agreement with you. In the case of anonymised data, however, not necessarily.

The decisive factor is the transmission to us, not the chosen test. We may only process personal data with an agreement. 

At the moment, we assume that a pure address check (you only transmit street, postcode and city) does not process any personal data. Just as little as a pure VAT ID number check. We do not need an order processing agreement for this.

Everything else is personal data, i.e. e-mail, telephone and name.

If you would now like to conclude our contract processing agreement electronically, you can do so here. Afterwards, you will receive an email with the contract documents including our technical-organisational measures (TOM). In addition to the brief instructions there, we have provided detailed instructions.

Alternatively, you can send us your version of the agreement. We will check it promptly and return it signed. You can download our TOM here, which saves paper and postage and is environmentally friendly.