What it says
What this says
Current to 11 Oct 26Executed Data Processing Agreement, effective 16 May 2025, under which BB-Demo Limited is Processor and Copperlane Payroll is Controller. It states no availability, P1 response time or price.
What it is: a short data processing agreement covering how BB-Demo processes Copperlane Payroll's personal data. It is signed by an authorised representative on each side on 16 May 2025, and the signatories are not named.
Commits: BB-Demo to process only on documented written instructions, keep staff under confidentiality, and not engage a sub-processor without written authorisation from the Controller. It must also delete or return personal data at the end of the services and allow audits and inspections.
Unusual: the text says it sits under the Master Service Agreement dated 1 Jun 2025, which is after its own effective date of 16 May 2025. The agreement does not say which came first in practice.
Not settled: no service levels, price, term, renewal or connector dates appear. Those sit in the order form and MSA, which this document does not contain.
As found in this document
Current to 9 Oct 26- Date signed16 May 2025Source: object_read:doc_022_005
- Date start16 May 2025Source: object_read:doc_022_005
- Processing instructionsThe Processor shall process Personal Data only on documented written instructions from the ControllerThe Processor shall process Personal Data only on documented written instructions from the Controller · Source: object_read:doc_022_005
- Sub-processorsThe Processor shall not engage any sub-processor without prior specific or general written authorisation from the ControllerThe Processor shall not engage any sub-processor without prior specific or general written authorisation from the Controller · Source: object_read:doc_022_005
- Deletion or returnAt the end of the provision of services, the Processor shall delete or return all Personal Data, and delete existing copies unless applicable law requires storageAt the end of the provision of services, the Processor shall delete or return all Personal Data, and delete existing copies unless applicable law requires storage · Source: object_read:doc_022_005
- Auditsallow for and contribute to audits and inspections by the Controller or the Controller's auditorsallow for and contribute to audits and inspections by the Controller or the Controller's auditors · Source: object_read:doc_022_005
The document
Body
Data Processing Agreement
Copperlane Payroll & BB-Demo Limited
Effective from: 16 May 2025
This Data Processing Agreement applies to the processing of Personal Data by BB-Demo Limited (the "Processor") on behalf of Copperlane Payroll (the "Customer" and "Controller") under the terms of the Master Service Agreement dated 1 June 2025.
1. Processing Instructions
The Processor shall process Personal Data only on documented written instructions from the Controller, including with regard to international transfers of Personal Data outside the United Kingdom, unless required to do so by applicable law.
2. Confidentiality
The Processor shall ensure that natural persons authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate legal obligation of confidentiality.
3. Security Measures
The Processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, having regard to the state of the art.
4. Sub-Processors
Read the whole document (2,194 characters)
The Processor shall not engage any sub-processor without prior specific or general written authorisation from the Controller. The Processor shall impose the same data protection obligations on any sub-processor by way of contract.
5. Rights of Data Subjects
The Processor shall, taking into account the nature of processing, assist the Controller by appropriate technical and organisational means in fulfilling the Controller's obligation to respond to data subject rights requests.
6. Deletion or Return of Personal Data
At the end of the provision of services, the Processor shall delete or return all Personal Data, and delete existing copies unless applicable law requires storage.
7. Demonstration of Compliance
The Processor shall make available to the Controller all information necessary to demonstrate compliance with this Agreement and shall allow for and contribute to audits and inspections by the Controller or the Controller's auditors.
Signatures
For Copperlane Payroll:
Authorised Representative
Date: 16 May 2025
For BB-Demo Limited:
Authorised Representative
Date: 16 May 2025
Unusual terms
Current to 9 Oct 26- Effective 16 May 2025, before the MSA dated 1 Jun 2025 it refers to