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Thanks. I mixed up the name, though, not the role. Your link says that the requirement for an EU rep "shall not apply to: processing which is occasional, does
by gcthomas 8y ago
Thanks. I mixed up the name, though, not the role.
Your link says that the requirement for an EU rep "shall not apply to: processing which is occasional, does not include, on a large scale, processing of special categories of data as referred to in Article 9(1) …"
Most companies will not need an EU Designated Representative, in the same way local companies will not need a DPO.
- jacquesm 8y agoOccasional and large scale may not mean quite what you think they do. Occasional: once per year but every year is not occasional. Large scale: more than a few thousand records. Keep in mind that the law is written for ordinary people, but tech people will interpret that totally different.
- gcthomas 8y agoAbsolutely, I agree. I was responding, specifically, to @rdlecler1 who claimed that "Yes, every US company must hire an EU representative to be compliant." Many small orgs, even if serving EU citizens, will not need an EU Resident Representative. And if they do, they should be able to contract to an EU company to represent them, rather than need to directly employ an individual.
- jacquesm 8y agoI'm looking at the idea of providing that service for charities and hobby projects for free. Still not quite sure about my own legal exposure.