Is a data sharing agreement required for Route 3 properties?
You will need to decide if data sharing agreements are necessary with any of the responsible persons for Route 3 properties you have identified in your area.
The information you receive from the responsible person will contain personal data, which is being shared between two data controllers. Whilst data protection legislation does not require a written agreement when sharing data between data controllers, it is nevertheless good practice to have a data sharing agreement in place.
Having a data sharing agreement in place with the responsible person will demonstrate that you are both acting in accordance with data protection legislation and will help to avoid any liability implications of one party being seen as a controller and the other being seen as a processor.
Our guidance on data protection for EROs and ROs provides information in relation to your role as data controller and a checklist to help inform the content of data sharing agreements.