What it says
What this says
Current to 11 Oct 26Executed Data Processing Agreement dated 26 Jan 2024 between BB-Demo Limited (Processor) and Tidecombe Housing (Controller). It covers personal data processed for the Company Brain service. It states no price, availability or response-time figures.
What it is: a signed DPA filed under the customer's Contracts folder, dated 26 Jan 2024. BB-Demo Limited is Processor and Tidecombe Housing is Controller, covering personal data in the customer's Snowflake account.
Commits: the Processor must "Process Personal Data only on documented instructions from Controller" and "Obtain prior written approval before engaging any sub-processor". Clause 8 keeps the DPA in force during the Service Agreement "and for one year thereafter for historical audit purposes".
Unusual: clause 5 names Snowflake as a sub-processor but only promises that the Controller "will be notified of any changes", which sits loosely beside the prior written approval duty in clause 4.
Not settled: no signatory names, no breach notification period, no data residency location, no service levels, price or renewal date. The Service Agreement it refers to is not identified here.
As found in this document
Current to 9 Oct 26- Date signed26 Jan 2024Source: object_read:doc_013_005
- Processing instructionsProcess Personal Data only on documented instructions from ControllerProcess Personal Data only on documented instructions from Controller · Source: object_read:doc_013_005
- Sub-processorsObtain prior written approval before engaging any sub-processorObtain prior written approval before engaging any sub-processor · Source: object_read:doc_013_005
- Sub-processor changesController will be notified of any changes to the sub-processor list.Controller will be notified of any changes to the sub-processor list. · Source: object_read:doc_013_005
- End of serviceDelete or return Personal Data at the end of service provision unless legislation requires storageDelete or return Personal Data at the end of service provision unless legislation requires storage · Source: object_read:doc_013_005
- Audit rightsController may audit Processor's compliance with this DPA upon reasonable notice.Controller may audit Processor's compliance with this DPA upon reasonable notice. · Source: object_read:doc_013_005
- Termremains in force during the Service Agreement and for one year thereafter for historical audit purposesremains in force during the Service Agreement and for one year thereafter for historical audit purposes · Source: object_read:doc_013_005
The document
Body
Tidecombe Housing - Data Processing Agreement
This Data Processing Agreement ("DPA") is entered into between BB-Demo Limited ("Processor") and Tidecombe Housing ("Controller"), as of 26 Jan 2024.
1. Scope
This DPA applies to personal data processed by Processor on behalf of Controller in the provision of the Company Brain service.
2. Definitions
"Personal Data" means any information relating to an identified or identifiable natural person. "Processing" means any operation performed on Personal Data.
3. Processing Details
3.1 Data Categories
Processor processes the following categories of Personal Data: contact information, call recordings, email communications, helpdesk records, product usage data and employment records as configured by Customer in Customer's Snowflake account.
3.2 Purposes
Personal Data is processed solely for the purpose of operating the Company Brain service, as instructed by Controller.
4. Processor Obligations
Read the whole document (1,946 characters)
Processor shall:
- Process Personal Data only on documented instructions from Controller
- Ensure personnel are bound by confidentiality
- Implement appropriate technical and organisational security measures
- Obtain prior written approval before engaging any sub-processor
- Assist Controller in responding to data subject rights requests
- Delete or return Personal Data at the end of service provision unless legislation requires storage
5. Sub-Processors
Processor may use sub-processors including Snowflake (data hosting). Controller will be notified of any changes to the sub-processor list.
6. Security
Processor implements encryption in transit and at rest, access controls, audit logging and regular security reviews.
7. Audit Rights
Controller may audit Processor's compliance with this DPA upon reasonable notice.
8. Term
This DPA remains in force during the Service Agreement and for one year thereafter for historical audit purposes.
Unusual terms
Current to 9 Oct 26- One-year post-service tail for audit
- Snowflake named as sub-processor with notification only on changes