When am I processing personal data on behalf of the controller?

If you are a coach in a sports team or instructor in other types of hobbies, you are probably working under a controller and processing personal data. For example, the hobby organiser may instruct you to collect the names and contact details of the participating children, or information on their health and allergies, when they start the hobby. You may also collect the contact details of the children’s custodians or other representatives so that the association can contact them when necessary. This kind of data collection counts as processing on behalf of the controller.

You need to take care when processing data. The controller should always have instructions for you on how you are allowed to process personal data. You can ask about processing instructions from the club’s or association’s administration, for example.