GDPR Article 26 — Joint controllers

What this control requires

Joint controllers must transparently define GDPR compliance responsibilities via an agreement, covering data subject rights and information duties (Articles 13, 14). The agreement, reflecting roles, must be accessible to data subjects, who can exercise rights against any controller. This control addresses Joint Controllers.

In plain English

Joint controllers must transparently define GDPR compliance responsibilities via an agreement, covering data subject rights and information duties (Articles 13, 14). In practice, this means you can prove you information controller-level controls on a defined cadence.

Why it matters

GDPR administrative fines reach the greater of €20 million or 4% of global annual turnover. The European Data Protection Board (EDPB) coordinates supervisory-authority enforcement across the EU/EEA, and DPAs publish enforcement decisions citing specific Articles.

What an auditor looks for

A DPA or privacy auditor expects: a Records of Processing Activities (RoPA) entry, a documented lawful basis, evidence the Article's data-subject right is operationalised end-to-end, a named DPO contact (where required), and Article 30 records that match what the front-end actually does.

Within Chapter IV: Controller and Processor, the assessor will trace your implementation back to the catalogue reference (Article Article 26) and look for objective evidence on the latest two assessment cycles.

How to implement

1. Write a short policy stating intent, scope and named owner.
2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

• Information. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Joint. Document the trigger, the owner and the cadence.
• Processor. Document the trigger, the owner and the cadence.
• Exercise. Document the trigger, the owner and the cadence.
• Scope: controller, controllers, rights, information, data subjects.

Evidence to collect

• Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Focus: Joint controllers.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• ISO/IEC 27001:2022 A.5.18 — Access rights
• BSI C5:2020 IDM-05 — Regular review of access rights
• SOC 2 (2017 TSC) CC1.5 — Accountability for Internal Control Responsibilities
• NIST SP 800-171 Rev. 3 3.13.4 — Information in Shared System Resources
• ISO/IEC 27701:2025 A.3.9 — Access rights

Related controls in GDPR

• Article Article 13 — Information to be provided where personal data are collected from the data subject
• Article Article 12 — Transparent information, communication and modalities for the exercise of the rights of the data subject
• Article Article 27 — Representatives of controllers or processors not established in the Union
• Article Article 28 — Processor
• Article Article 33 — Notification of a personal data breach to the supervisory authority
• Article Article 34 — Communication of a personal data breach to the data subject

References

• European Union — GDPR
• Catalogue identifier: Article Article 26

Topics: identity accessidentity managementaccess reviewprivileged access