Draft

Data processing agreement (DPA)

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The binding text must come from your legal counsel. The headings below are a skeleton showing which topics will be covered.

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1 · Roles

In the cloud version the customer is controller and Talya Smart, Inc. is processor. No DPA is needed for self-host installations.

2 · Subject matter and duration

The nature and purpose of processing, data categories and categories of data subjects; duration follows the subscription.

3 · Instructions

The processor acts only on the controller’s documented instructions.

4 · Confidentiality and personnel

Confidentiality obligations of authorised personnel and the least-privilege principle.

5 · Technical and organisational measures

Encryption, access logs, backups, environment separation and penetration-testing scope.

6 · Sub-processors

The approved sub-processor list, change notification and the right to object.

7 · International transfers

Transfer mechanisms (SCCs / undertakings), categories of transferred data and countries.

8 · Breach notification and audit

Breach notification timing, information to be provided, audit rights and deletion/return obligations.

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