GDPR Article 28 requires controllers to engage only processors that provide sufficient guarantees for appropriate technical and organisational measures. A legally sound data processing agreement (DPA) governs the subject matter, duration, purpose and security measures of data processing. ADVISORI supports you in selecting and assessing processors, drafting your DPA and establishing ongoing monitoring – practical, legally compliant and efficient.
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Without a valid DPA, sharing personal data with service providers is unlawful. Article 28 GDPR requires documented instructions, technical and organisational measures and clear sub-processor provisions. Fines for violations can reach 10 million euros.
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We develop a structured approach to data processing with you – from taking stock through contract drafting to ongoing monitoring of your processors.
Inventory of all service providers and existing data processing agreements
Risk assessment and prioritisation based on the sensitivity of data processed
DPA drafting or revision with all mandatory content under Article 28 GDPR
Establishing regular audit and review processes for data processors
Ongoing monitoring and documentation for accountability under Article 5(2) GDPR
"ADVISORI provided invaluable support in redesigning our data processing agreements and introducing a structured processor assessment process. Through systematic evaluation of our processors and clear assessment criteria, we significantly improved data protection compliance across our supplier chain."

Head of Information Security, Cyber Security
Expertise & Experience:
10+ years of experience, CISA, CISM, Lead Auditor, DORA, NIS2, BCM, Cyber and Information Security
We offer you tailored solutions for your digital transformation
We draft and review data processing agreements under Article 28 GDPR covering all mandatory content – subject matter, duration, TOMs, instruction obligations, sub-processors and deletion provisions.
We assess your data processors systematically: reviewing technical and organisational measures, certifications, data protection concepts and references before engagement.
We establish contractual and organisational frameworks for sub-processors – with authorisation procedures, notification obligations and enforcement rights under Article 28(2) and (4) GDPR.
We establish regular review and audit processes for existing processors – from annual reviews through event-driven audits to compliance evidence.
We advise on data transfers to third countries – with standard contractual clauses, transfer impact assessments and adequacy decisions under GDPR Chapter V.
We train your business units and procurement teams on data protection requirements for processor selection and integrate DPA processes into existing procurement workflows.
Choose the area that fits your requirements
The General Data Protection Regulation places complex requirements on AI systems through privacy-by-design principles, automated decision-making compliance, transparency obligations and algorithmic accountability for secure AI data processing. Successful GDPR AI compliance management goes beyond traditional data protection approaches and creates integrated AI governance systems that smoothly connect AI innovation, regulatory compliance and operational efficiency. We develop tailored AI compliance frameworks that not only meet regulatory requirements, but also unlock strategic AI business opportunities, minimise risks and establish sustainable competitive advantages through superior AI governance and AI data protection excellence.
Art. 30 GDPR requires asset managers and fund management companies to document all processing activities involving personal data without gaps. A structured data inventory forms the foundation for records of processing activities, retention policies and the implementation of data subject rights. We support financial services firms from initial assessment through the creation of records of processing activities to audit-ready documentation of technical and organisational measures.
The General Data Protection Regulation presents banks and financial service providers with unique challenges due to complex customer data processing, cross-border data transfers, and strict regulatory requirements. Successful GDPR compliance in the banking sector requires more than standardized data protection approaches — it requires specialized banking expertise that smoothly connects data protection law with financial regulation. We develop tailored GDPR banking frameworks that not only ensure legal compliance but also increase operational efficiency, strengthen customer trust, and establish sustainable competitive advantages through superior data protection governance in the financial sector.
The General Data Protection Regulation places complex requirements on cloud computing environments through cross-border data transfer compliance, cloud provider due diligence, data residency requirements and multi-cloud governance structures for secure cloud data processing. Successful GDPR cloud computing management goes beyond traditional data protection approaches and creates integrated cloud governance systems that smoothly connect cloud privacy, vendor management and operational efficiency. We develop tailored cloud compliance frameworks that not only meet regulatory requirements but also unlock strategic cloud business opportunities, minimise risks and establish sustainable competitive advantages through superior cloud governance and cloud data protection excellence.
The General Data Protection Regulation places complex requirements on international data transfers through adequacy decisions, standard contractual clauses, and transfer impact assessments for secure cross-border data transmission. Successful cross-border transfer management goes beyond traditional compliance approaches and creates integrated governance systems that smoothly connect international data transfer security, regulatory compliance, and operational efficiency. We develop tailored transfer frameworks that not only meet regulatory requirements but also enable strategic international business opportunities, minimize risks, and establish sustainable competitive advantages through superior cross-border governance and international data protection excellence.
The General Data Protection Regulation places complex demands on data breach response management through time-critical notification compliance, comprehensive data subject rights fulfilment, regulatory authority communication and systematic post-breach recovery processes for sustainable data protection governance. Successful GDPR breach response management goes beyond traditional incident response approaches and creates integrated governance systems that smoothly connect breach prevention, rapid response and stakeholder communication. We develop tailored breach response frameworks that not only meet regulatory requirements but also enable strategic business continuity, minimise reputational risks and establish lasting competitive advantages through superior incident management governance and data protection excellence.
The General Data Protection Regulation (GDPR) requires systematic and sustainable implementation. We support you in the complete fulfillment of all data protection requirements.
Insurance companies process particularly sensitive personal data — from health data and creditworthiness information to risk profiles. The GDPR therefore imposes stringent requirements on the insurance sector: legal bases under Art. 6 and Art. 9, consent management, data protection impact assessments for scoring and profiling, and deletion concepts that account for insurance-specific retention obligations. We advise insurers on the practical implementation of all GDPR obligations — legally compliant, efficient and aligned with industry-specific regulations such as codes of conduct under Art. 40 GDPR and national insurance supervision requirements.
Ensure continuous compliance with GDPR requirements through our comprehensive ongoing compliance approach. We establish data protection governance structures, automated monitoring mechanisms, and proactive adaptation processes that guarantee lasting compliance and sustainably minimize data protection risks.
The General Data Protection Regulation places complex demands on Privacy-by-Design implementation through proactive privacy protection, privacy-as-default settings, privacy-embedded design, and full-functionality privacy balance for sustainable data protection governance. Successful GDPR Privacy-by-Design management goes beyond traditional compliance approaches and creates integrated privacy systems that smoothly connect privacy engineering, data minimization, and user privacy rights. We develop tailored Privacy-by-Design frameworks that not only meet regulatory requirements but also enable strategic business innovation, minimize privacy risks, and establish sustainable competitive advantages through superior privacy governance and data protection excellence.
A professional GDPR readiness assessment reveals where your organisation stands on data protection. We evaluate your current maturity level, uncover compliance gaps, and develop a prioritised roadmap to full GDPR conformity.
Data processing applies when a service provider (processor) processes personal data on behalf of and under the instructions of the controller. Typical examples include cloud hosting, external payroll processing, newsletter dispatch, IT maintenance with data access, and data carrier disposal. Purely postal services, telecommunications or banking services do not constitute data processing under Article 28.
Article 28(3) GDPR defines mandatory content: subject matter and duration of processing, nature and purpose of processing, types of personal data, categories of data subjects, and obligations and rights of the controller. Additionally, the DPA must address binding instructions, confidentiality, technical and organisational measures, sub-processor arrangements, data subject rights assistance, deletion after contract end, and audit rights.
The controller must verify the processor has appropriate technical and organisational measures. Assessment methods include on-site audits, reviewing certifications (ISO 27001, SOC 2, BSI C5), examining TOM documentation, checking references and data protection concepts. The assessment must be documented and repeated at regular intervals.
Article 28(2) GDPR requires the processor not to engage another processor without prior authorisation from the controller. The DPA must specify whether general or specific authorisation applies, how changes are communicated, and which contractual obligations must be passed on to sub-processors. The processor remains liable for its sub-processors.
Under Article
82 GDPR, both controller and processor are jointly liable to data subjects. The controller is liable for the entire processing, the processor only for violations of its specific obligations or instructions. Fines under Article
83 GDPR can affect both parties – up to EUR
20 million or 4% of annual turnover.
Article 28(3)(g) GDPR stipulates that the processor must delete or return all personal data after the end of processing – at the controller choice – and destroy existing copies. The DPA should specify concrete deadlines, return formats and deletion certificates. Statutory retention obligations of the processor remain unaffected.
In data processing (Article
28 GDPR), the service provider acts under instructions for the controller. In joint controllership (Article
26 GDPR), two or more controllers jointly determine the purposes and means of processing. The distinction is crucial: joint controllership requires an arrangement under Article
26 GDPR instead of a DPA, specifying respective responsibilities and contact points for data subjects.
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