My Experience Before A Data Privacy Commission
My experience - I've been called in front of the Office for Personal Data Protection – Macao SAR Government, including their legal staff and asked what I do, how I get the information, and what I do with it.
It went back and forth but was finally deemed that I am a sub-contractor - not a processor or a controller.
They explained to me that someone (in your capacity as a CRA) is a processor and your client (if they are the originator) would be the controller.
Me? Just a sub-contractor.
The meeting took all afternoon.