Agent skill

Joint Controller Art26

by mukul975 in mukul975/Privacy-Data-Protection-Skills

Guides the establishment and management of joint controller arrangements under GDPR Article 26, including determination of joint controllership, allocation of responsibilities, and transparency…

Apache-2.0Auto-check passedLegal & Compliance

Install Joint Controller Art26

skills CLI
$ npx skills add mukul975/Privacy-Data-Protection-Skills --skill joint-controller-art26 -a claude-code

Project install by default; add -g for ~/.claude/skills/.

GitHub CLI
$ gh skill install mukul975/Privacy-Data-Protection-Skills joint-controller-art26 --agent claude-code

Project scope by default; add --scope user for a personal install. Needs GitHub CLI 2.90.0 or later (public preview).

Manual copy
$ git clone --depth 1 https://github.com/mukul975/Privacy-Data-Protection-Skills.git skills-src && mkdir -p .claude/skills && cp -r skills-src/skills/privacy/joint-controller-art26 .claude/skills/joint-controller-art26 && rm -rf skills-src

Use ~/.claude/skills/ instead of .claude/skills for a personal install. The folder must contain SKILL.md.

Claude Code skills documentation · loads skills from .claude/skills/

Facts

Skill name
joint-controller-art26
GitHub stars
297
Token cost
~1.7k tokens
SKILL.md length
797 words
Files
5 (incl. scripts, references, assets)
Skills in repo
280
Repo updated
First seen
Licence
Apache-2.0

At a glance

Guides the establishment and management of joint controller arrangements under GDPR Article 26, including determination of joint controllership, allocation of responsibilities, and transparency…

  • Works in 3 steps: Respective Responsibilities → Contact Point for Data Subjects → Transparency
  • Tasks that involve Privacy and GDPR
  • SKILL.md covers Overview, Determining Joint Controllership, Art. 26 Arrangement Requirements and Arrangement Template Structure, plus 1 more section
  • Runs Python scripts from its folder

What it does

Joint Controller Art26 is an agent skill from mukul975/Privacy-Data-Protection-Skills. Guides the establishment and management of joint controller arrangements under GDPR Article 26, including determination of joint controllership, allocation of responsibilities, and transparency obligations. Activate when two or more controllers jointly determine purposes and means of processing, or when evaluating shared data platforms. Keywords: joint controller, Article 26, shared responsibility, arrangement, joint determination.

Its SKILL.md is about 1.7k tokens, which your agent loads only when the skill is triggered. The skill folder holds 7 other files, including scripts, reference files and assets (for example `assets/template.md`, `references/standards.md` and `references/workflows.md`).

It sits in Legal & Compliance, covering Privacy and GDPR. The repository describes itself as: 282+ structured privacy & data protection skills for AI agents. GDPR, CCPA, EU AI Act, HIPAA, LGPD, PIPL, DPDP Act. The licence is Apache-2.0.

When your agent uses it

  • Tasks that involve Privacy and GDPR

Example prompts

  • “Use the joint-controller-art26 skill to guide the establishment and management of joint controller arrangements under GDPR Article 26, including…”
  • “/joint-controller-art26”

Requirements

  • Python 3

Workflow steps

3 steps, taken from the step headings in SKILL.md.

  1. Respective Responsibilities
  2. Contact Point for Data Subjects
  3. Transparency

What it can do on your machine

Read from SKILL.md and the folder at commit 9b2ef9e. It shows what the files ask for, not the result of running them.

  • Tool permissions

    Pre-approves nothing: there is no allowed-tools line, so your agent's usual permission prompts apply.

    From allowed-tools in the SKILL.md frontmatter.

  • Runs code

    Ships 1 file in scripts/ (Python), which the agent can run.

    From the folder's file list and the shell code blocks in SKILL.md.

  • Network

    No URLs in SKILL.md.

    From URLs in SKILL.md, links to its own repository left out.

  • Credentials

    Names no API keys, tokens, secrets or passwords.

    From names ending in _API_KEY, _TOKEN, _SECRET, _KEY or _PASSWORD in SKILL.md.

Context cost

Joint Controller Art26 loads about 1.7k tokens when it runs, and up to ~4k if it reads all its reference files. Until then it costs about 115 tokens; SKILL.md has 797 words of instructions outside code blocks.

Always · name and description, kept in context so the agent knows when to use it
~115
When it runs · the whole SKILL.md, loaded when a task matches
~1.7k
With references · SKILL.md plus every file in references/, read only if the agent opens them
~4k

Estimates: characters ÷ 4, the usual rule of thumb; real counts depend on the model's tokenizer. Scripts and assets cost tokens only if the agent reads them.

Safety

Auto-check passed

The automated check found no risky patterns in SKILL.md.

Automated static check — not a guarantee. Review scripts before installing. It scans the text of SKILL.md for risky patterns (piping downloads into a shell, reading credential files, hidden Unicode, destructive commands); the scripts in this folder are not scanned.

SKILL.md

The full file from mukul975/Privacy-Data-Protection-Skills at commit 9b2ef9e, republished under its Apache-2.0 licence (© mukul975). 797 words, ~1,688 tokens.

Download SKILL.mdSave it as .claude/skills/joint-controller-art26/SKILL.md (or your agent's skills folder). This skill also uses 4 other files; get the full folder from GitHub.
name
joint-controller-art26
description
Guides the establishment and management of joint controller arrangements under GDPR Article 26, including determination of joint controllership, allocation of responsibilities, and transparency obligations. Activate when two or more controllers jointly determine purposes and means of processing, or when evaluating shared data platforms. Keywords: joint controller, Article 26, shared responsibility, arrangement, joint determination.
license
Apache-2.0
metadata.author
mukul975
metadata.version
1.0
metadata.domain
privacy
metadata.subdomain
gdpr-compliance
metadata.tags
gdpr, joint-controller, article-26, shared-processing, arrangement, responsibility

Managing Joint Controller Arrangements

Overview

Article 26 applies when two or more controllers jointly determine the purposes and means of processing. Joint controllers must enter into an arrangement that transparently determines their respective responsibilities for compliance, particularly regarding data subject rights and transparency obligations. The essence of the arrangement must be made available to data subjects.

Determining Joint Controllership

Joint controllership exists when two or more entities:

  1. Jointly determine the purposes — both entities influence why data is processed.
  2. Jointly determine the means — both entities influence how data is processed (essential means, not just technical implementation details).
Key Indicators
IndicatorPoints to Joint ControllershipPoints Away
Shared decision on purposeBoth parties decide why data is processedOne party decides purpose; other merely executes
Shared platformBoth parties upload/access data on a common platformOne party hosts; other merely provides input
Shared datasetBoth parties contribute to and benefit from a combined datasetOne party processes only for the other's purpose
Mutual benefitBoth parties derive independent benefit from the processingOnly one party benefits; other is purely a service provider
Influence on meansBoth parties have a say in essential aspects (what data, how long, who accesses)One party determines all essential means; other party only implements
CJEU Case Law Guidance
  • Wirtschaftsakademie Schleswig-Holstein (C-210/16): A Facebook fan page admin is a joint controller with Facebook because the admin's creation of the page enables Facebook's processing and the admin benefits from visitor statistics.
  • Jehovah's Witnesses (C-25/17): A religious community that organises door-to-door preaching and coordinates personal data collection by its members is a joint controller with those members.
  • Fashion ID (C-40/17): A website embedding a Facebook Like button is a joint controller with Facebook for the collection and transmission of data triggered by the plugin.

Art. 26 Arrangement Requirements

The arrangement between joint controllers must determine in a transparent manner:

1. Respective Responsibilities
Responsibility AreaAllocation Options
Lawful basis determinationWhich controller is responsible for establishing and documenting the lawful basis
Privacy notices (Art. 13-14)Which controller provides transparency information to data subjects
Data subject rights (Art. 15-22)Which controller serves as the contact point and handles requests
Data security (Art. 32)Which controller implements and maintains security measures
Breach notification (Art. 33-34)Which controller notifies the supervisory authority and data subjects
DPIA (Art. 35)Which controller conducts the DPIA
Records of processing (Art. 30)How both controllers maintain their respective RoPA entries
2. Contact Point for Data Subjects

The arrangement must designate a contact point for data subjects. Regardless of the arrangement, data subjects may exercise their rights against any of the joint controllers (Art. 26(3)).

3. Transparency

The essence of the arrangement must be made available to data subjects. This does not require publishing the full commercial agreement, but must cover:

  • The identity of both joint controllers
  • How responsibilities are divided
  • How data subjects can exercise their rights
  • The designated contact point
Show full SKILL.md (312 more words)Show less

Arrangement Template Structure

A compliant Art. 26 arrangement should include:

  1. Parties and definitions: Legal entity names, registered addresses, roles.
  2. Scope of joint processing: Specific processing activities covered, personal data categories, data subject categories.
  3. Purpose determination: How purposes are jointly determined and what each party's interest is.
  4. Means determination: Which essential means each party determines (data elements, retention, access, security standards).
  5. Responsibilities allocation: Detailed allocation per the table above.
  6. Data subject rights: Designated contact point, handling procedures, cooperation obligations.
  7. Transparency: How the essence of the arrangement is communicated to data subjects.
  8. Security obligations: Minimum security standards each party commits to.
  9. Breach management: Notification obligations between the parties and to authorities/data subjects.
  10. Liability: Internal allocation of liability (note: external liability to data subjects is joint and several per Art. 82(4)-(5)).
  11. Term and termination: Duration, exit provisions, and data handling upon termination.

Practical Considerations

Joint and Several Liability

Under Art. 82(4), each joint controller is liable for the entire damage caused by processing that infringes the GDPR. A joint controller may be exempted from liability under Art. 82(3) only if it proves it is not responsible for the event giving rise to the damage. Internal liability allocation in the arrangement does not affect the data subject's right to claim against either controller.

Supervisory Authority Actions

Under Art. 26(3), data subjects can exercise their rights against each and any of the joint controllers regardless of the arrangement. The supervisory authority may also investigate any joint controller for the full scope of joint processing.

Relationship with Art. 28

Joint controllership and the controller-processor relationship are mutually exclusive for a given processing activity. If Entity A determines purposes and means and Entity B merely processes on A's instructions, the relationship is controller-processor (Art. 28). If both determine purposes and means, the relationship is joint controllership (Art. 26).

© mukul975, Apache-2.0. Rendered from Markdown: HTML in the file is shown as text, images as links, and headings moved down two levels. Raw file

Files

SKILL.md and 4 other files (scripts, references, assets) in skills/privacy/joint-controller-art26 of mukul975/Privacy-Data-Protection-Skills.

  • SKILL.md
  • assets/template.md
  • references/standards.md
  • references/workflows.md
  • scripts/process.py

Open the folder on GitHubat commit 9b2ef9e

Compare with similar skills

Joint Controller Art26 next to the 5 skills that share the most tags, products or categories with it. Stars are the repository's; “used in” counts other GitHub owners with a copy.

Joint Controller Art26 compared with similar skills
SkillStarsUsed inTokensAuto-checkLicenceRepo updated
Joint Controller Art26 this skillmukul975/Privacy-Data-Protection-Skills297—~1.7kAutomated safety check: PassApache-2.0
C15tc15t/c15t1.9k1 repos~1.6kAutomated safety check: PassApache-2.0
HIPAA Safe Harbor Coverage Auditmaziyarpanahi/openmed5.5k—~1.7kAutomated safety check: PassApache-2.0
Korean Privacy Termskimlawtech/korean-privacy-terms586—~2.9kAutomated safety check: PassApache-2.0
Gdpr ComplianceSushegaad/Claude-Skills-Governance-Risk-and-Compliance9431 repos~3.9kAutomated safety check: PassMIT
Hipaa ComplianceSushegaad/Claude-Skills-Governance-Risk-and-Compliance9431 repos~2.3kAutomated safety check: PassMIT

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Questions about Joint Controller Art26

What does Joint Controller Art26 do?

Guides the establishment and management of joint controller arrangements under GDPR Article 26, including determination of joint controllership, allocation of responsibilities, and transparency…. Joint Controller Art26 is an agent skill from mukul975/Privacy-Data-Protection-Skills. Guides the establishment and management of joint controller arrangements under GDPR Article 26, including determination of joint controllership, allocation of responsibilities, and transparency obligations.

When should I use Joint Controller Art26?

Joint Controller Art26 fits situations like: tasks that involve Privacy and GDPR.

How do I install Joint Controller Art26 in Claude Code?

Run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill joint-controller-art26 -a claude-code`. Or copy the skill folder (skills/privacy/joint-controller-art26 in mukul975/Privacy-Data-Protection-Skills) into .claude/skills/joint-controller-art26 in your project. Claude Code loads it when a task matches its description.

How do I install Joint Controller Art26 in Codex?

Run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill joint-controller-art26 -a codex`. Or copy the skill folder (skills/privacy/joint-controller-art26 in mukul975/Privacy-Data-Protection-Skills) into .agents/skills/joint-controller-art26 in your project. Codex loads it when a task matches its description.

Can I use Joint Controller Art26 in Cursor, Gemini CLI or GitHub Copilot?

Cursor, Gemini CLI, GitHub Copilot and OpenCode also load SKILL.md folders. With the skills CLI, run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill joint-controller-art26 -a cursor` (or -a gemini-cli, github-copilot or opencode for the others). To copy it by hand, put the folder in .cursor/skills/joint-controller-art26, .gemini/skills/joint-controller-art26, .github/skills/joint-controller-art26 and .opencode/skills/joint-controller-art26 in your project.

What does Joint Controller Art26 need to run?

Going by SKILL.md and its folder, Joint Controller Art26 needs Python for the scripts in its folder. Our summary lists: Python 3.

Does Joint Controller Art26 access the network?

SKILL.md contains no URLs. Any network use would come from the scripts or tools the agent runs. This is read from the text; nothing was executed.

Is Joint Controller Art26 safe to install?

Our automated static check of SKILL.md found no risky patterns, such as piping downloads into a shell, reading credential files or hidden Unicode. It is not a guarantee. The check reads SKILL.md only: the scripts in the folder are not scanned, so read them before running anything.

What licence does Joint Controller Art26 use?

Joint Controller Art26 is published under the Apache-2.0 licence (declared in SKILL.md). It allows redistribution, so the full SKILL.md is shown on this page.

How many tokens does Joint Controller Art26 use?

About 1.7k tokens (SKILL.md is roughly 6.8k characters). Agents keep only the skill's name and description in context until a task matches; then they load SKILL.md in full. Its references folder adds about 2.3k tokens, read only when the agent opens those files.

What are the alternatives to Joint Controller Art26?

Skills that share tags, products or a category with Joint Controller Art26: C15t (c15t/c15t, 1.9k stars), HIPAA Safe Harbor Coverage Audit (maziyarpanahi/openmed, 5.5k stars), Korean Privacy Terms (kimlawtech/korean-privacy-terms, 586 stars) and Gdpr Compliance (Sushegaad/Claude-Skills-Governance-Risk-and-Compliance, 943 stars). The comparison table on this page puts their stars, adoption, token cost, safety result and licence side by side.

Who maintains Joint Controller Art26?

mukul975 (a GitHub user) maintains it in mukul975/Privacy-Data-Protection-Skills, which has 297 GitHub stars. The repository holds 280 skills in this directory. The repository was last updated on March 16, 2026.

Source: mukul975/Privacy-Data-Protection-Skills on GitHub. Facts on this page come from the repository at the commit we read; the author's words are quoted as theirs.