D.GDPR.HuDSH-St.1
Personal data Data has no data controller: under the GDPR, a data controller (a person or in most cases, an organisation) who alone or jointly with others, determines the purposes and means of the processing of personal data, and has certain responsibilities defined by Article 24. Data Data relates to the data subject DataSubject and is subject to the GDPR, so there should be a controller. Add an organisation or user if not already included, and a hasController relationship from Data to its data controller.