IT maintenance is ‘Data processing on behalf’ according to German DPAs

Abstract

With the application of the GDPR the question arises, How to qualify IT maintenance? This aspect is of great relevance since any software contains personal data. Microsoft, Oracle and SAP, for example, process personal data of customers and employees. Similarly, reporting software, which only stores financial data of the controller, contains at least the name or the ID of the employees who are using the software for access management.