A cloud processor established in Ireland processes personal data only for non-EU controllers about individuals who are not in the Union. How should Article 3 be approached?
Select an answer to reveal the explanation.
Short Explanation
Picture a Dublin warehouse that stores boxes for overseas shops about overseas customers — the warehouse itself still sits under Union rules. Establishment of the processor can matter even if the client and the people in the files are abroad. Ignoring the Irish footprint is the trap.
Full Explanation
Article 3(1) applies to processing in the context of activities of an establishment of a controller or a processor in the Union. Processor establishment is therefore independently relevant. Non-EU controllers and non-EU data subjects do not automatically erase GDPR duties for an EU-based processor. Role as a pure processor does not require also being a marketing controller to trigger scope analysis.