Article 4 Roles and responsibilities for processing personal data in the DSA data access portal

This article establishes the data protection roles of the key actors involved in the DSA data access portal.

It draws a clear distinction between Digital Services Coordinators, who act as independent controllers of personal data in managing the data access process, and the Commission, which acts only as a processor of personal data within the portal.

This distinction is significant in the context of EU data protection law, as it determines who bears ultimate responsibility for how personal data is used versus who merely handles it on another party's behalf.

Important points:

• Digital Services Coordinators are designated as separate controllers for personal data processed in managing the data access process and publishing relevant information.
• The Commission is designated as a processor of personal data within the DSA data access portal, not a controller.
• The Commission's specific responsibilities as processor are defined in the Annex to the regulation.