Cruxi
Service decision and evidence guide
Representative appointment needs an operational handoff. EDPB guidance separates the controller/processor’s responsibility for primary processing-record content and updates from the representative’s ability to maintain and make the record available. It also describes facilitating rights and authority communications. Specify the evidence flow and decision owner before signing.
Evidence retrieved 2026-10-07. Source versions and topic-specific limits are listed below.
Sourced criteria · EU · GDPR
| Decision or task | What the source describes | What to prepare |
|---|---|---|
| Primary content and updates | The guidance places primary processing-record content and updates with the controller/processor, which supplies accurate updated information to the representative. [1] | Compare the stated example/criterion with the evidence tasks below; retain any factual differences. |
| Record availability | Article 30 sets processing-record requirements for the relevant controller/processor and representative. Determine the applicable contents and exceptions for the actual activity. [3] | Compare the stated example/criterion with the evidence tasks below; retain any factual differences. |
| Enquiry facilitation versus decisions | The guidance explains that the representative facilitates communication about rights and authority enquiries; the represented controller/processor retains its responsibility. [1] [2] | Compare the stated example/criterion with the evidence tasks below; retain any factual differences. |
The EDPB document is Guidelines 3/2018, version 2.1, adopted 12 November 2019. Its worked examples are guidance and dated assumptions, not a new law or a conclusion about your organisation. EU scope is assessed here; UK and Swiss rules require separate evidence. Novel or disputed scope/role interpretations need specialist legal review.
Use this checklist to gather your business or product details before speaking with a specialist. The items below explain what to record and suggest useful supporting documents. You can add your own answers in the editable project brief.
Identify who owns content, affected activities, current versions and unresolved record requirements.
Useful evidence: A processing-record inventory with internal owners and version history.
Specify how changes reach the representative, who acknowledges them and how the current record can be produced when needed.
Useful evidence: An update/acknowledgement workflow and controlled document-access procedure.
Agree identity checks, routing, internal decision ownership and effective communication with people and authorities; confirm contract exclusions.
Useful evidence: A redacted enquiry-routing test and responsibility matrix.
Read the official document in context. The audit details identify the precise locators and preserved versions used for this page.
Guidelines 3/2018 version 2.1; 2020-01-07 formatting change · retrieved 2026-10-07
Source key D17 · snapshot d6910de864b8bbbdd7ed11e7509391a21ac9b627c8745dde87e8acd7c63b4862
Consolidated text dated 2016-05-04 · retrieved 2026-10-06
Source key D05 · snapshot 149156a8f8dfc90bead21c89c32eb84f92b7414602c3e00e058755810b48ef8a
Confirm the facts, scope and contact preference before sharing your project. Preparing this page sends no provider outreach.