Using a Data Processing Agreement with Subcontractors
Put your data processing agreement in place before a processor or sub-processor gets access to personal data. If you use a processor, UK GDPR guidance requires a [written contract or other legal act](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/accountability-and-governance/contracts-and-liabilities-between-controllers-and-processors-multi/when-is-a-contract-needed-and-why-is-it-important). Set that contract boundary before support logins, shared folders, or troubleshooting access turn into live processing.
