The test is decision-making
Controllership is a factual question about who decides the purposes and means of processing, not a label chosen in a contract. If you decide to run an advertising pixel on your site, you determined the purpose, and you are the controller for that processing.
Under StrongPrivacy’s intended arrangement, the customer determines the website technologies and purposes and StrongPrivacy processes the resulting visitor evidence on instruction. Contracts describe that intended allocation, but actual purposes and means determine the role; StrongPrivacy can be a controller for its own account, billing, security or other independently determined processing.
What follows from being the controller
- The consent obligation is yours; a tool can help you meet it and cannot assume it
- The demonstrability duty is yours, which is why the records are exportable
- Data subject requests come to you, and the register exists to track them
- Choosing vendors, including this one, is a controller decision with its own diligence
Common questions
Is the consent platform a joint controller?
Not merely because it supplies software. In the intended StrongPrivacy workflow the customer chooses the technologies and purposes and the platform follows instructions, but actual conduct controls. If the parties jointly determine relevant purposes or essential means, joint controllership can arise regardless of the contract label.
Does using a consent tool transfer the obligation?
No. It gives you the mechanism and the evidence. The obligation to have a lawful basis, to inform, and to be able to demonstrate consent stays with the controller.
Sources and verification
Verified on . Product-behaviour statements were checked against the current implementation and tests. The links below are the verification basis recorded for this article. They support the stated facts, not a legal conclusion for every site or configuration; recheck changing vendor behaviour before relying on it in production.
- Regulation (EU) 2016/679 (GDPR)
Legislation
Checked
See what your own site is loading
A browser scan reports the requests and storage it observed during the sampled journey. Use configured workspace scans to compare the states and pages that matter to your implementation.