The Internet of Things (IoT) is a leading trend with numerous opportunities accompanied by advantages as well as disadvantages. Parallel with IoT development, significant privacy and personal data protection challenges are also growing. In this regard, the General Data Protection Regulation (GDPR) is often considered the world’s strongest set of data protection rules and has proven to be a catalyst for many countries around the world. The concepts and interaction of the data controller, the joint controllers, and the data processor play a key role in the implementation of the GDPR. Therefore, clarifying the blurred IoT actors’ relationships to determine corresponding responsibilities is necessary. Given the IoT transformation reflected in shifting computing power from cloud to the edge, in this research we have considered how these computing paradigms are affecting IoT actors. In this regard, we have introduced identification of IoT actors according to a new five-computing layer IoT model based on the cloud, fog, edge, mist, and dew computing. Our conclusion is that identifying IoT actors in the light of the corresponding IoT data manager roles could be useful in determining the responsibilities of IoT actors for their compliance with data protection and privacy rules.
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