Liquidators were not ‘data controllers’ for the purposes of the Data Protection Act 1998

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Where a company processing personal data enters liquidation, the liquidators are not the ‘data controllers’ pursuant to the Data Protection Act 1998 (DPA), in respect of personal data processed by the company.

As such, the liquidators are not personally liable for compliance with the DPA in respect of that data.

Consequently, they may dispose of such data save where it is required to: a) respond to existing data subject access requests (DSAR); or b) enable the liquidators to deal with claims in the liquidation…

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