Glossary
Data controller
Under GDPR, whoever decides why and how personal data is processed. When someone fills in your card page, you are the controller of that contact, because it is collected for your purposes.
Article 4(7) of the GDPR defines the controller as whoever determines the purposes and means of processing. The test is decision, not possession: the party that decides why the data is collected is the controller, whichever server it happens to sit on.
Applied to a card page, the answer is you. You put the card in front of someone, you decided you wanted their details, and you will decide what to do next with them. LeadShake holds the row but chose none of that, which makes it the processor.
What the role puts on you
Four things, and none of them is heavy at the scale of a fair.
A purpose you can state in a sentence, decided before the collection and not after. A lawful basis, which for lead capture is the consent ticked on the form. An answer within one month if the person asks what you hold, asks for a correction, or asks to be erased. And a limit: data collected to follow up on a conversation cannot quietly become a mailing list, because that is a new purpose the person never agreed to.
Two roles on the same account
For your own account details, the ones you typed when you signed up, Kern IT is the controller and you are the person concerned. For the contacts you capture, the roles swap.
Both are true at once, and the practical consequence is short: the person who filled in your form writes to you, and you write to us.
Questions
Yes. You decided to collect them and you decide what happens next, which is the test article 4(7) sets. LeadShake stores them on your instructions and chose none of it.
Related terms
- Data processor
- Under GDPR, whoever processes personal data on a controller’s instructions. LeadShake is the processor for the leads you capture: it stores, emails and exports them for you, and does nothing else with them.
- Lead capture
- Collecting the contact details of someone you met, with their agreement, so you can follow up. It is the reverse of a business card: instead of giving your details away, you record theirs.
- Data enrichment
- Completing a contact you collected by matching it against outside databases, often bought from data brokers. Several lead capture tools sell it as a feature. LeadShake does not do it, so a record only ever contains what the person typed.