What it says
What this says
Current to 11 Oct 26Executed data processing agreement signed on 23 Dec 2024. Kingdon Diagnostics is controller and BB-Demo is processor, under the master services agreement. It states no price, availability or P1 response figures.
What it is: an executed DPA under the master services agreement, governing personal data processed for the company brain service. It was signed on 23 Dec 2024 for BB-Demo by Tom Ashdown, Account Executive.
Commits: BB-Demo to process data "only on the documented instructions of the customer", to apply security measures, to notify breaches "without undue delay", and to return or delete data at the end of the service.
Unusual: no transfer outside the United Kingdom without a lawful mechanism and notice to the customer. Sub-processors are under general authorisation, with notice of changes so the customer can object.
Not settled: the customer signatory is named only as "Authorised signatory". No breach deadline in hours, no price, no service levels and no renewal date are stated. Liability limits sit in the master services agreement.
As found in this document
Current to 9 Oct 26- Date signed23 Dec 2024Source: object_read:doc_083_006
- Processing instructionsprocess personal data only on the documented instructions of the customerprocess personal data only on the documented instructions of the customer · Source: object_read:doc_083_006
- Personal data breach noticenotify the customer without undue delay after becoming aware of a personal data breachnotify the customer without undue delay after becoming aware of a personal data breach · Source: object_read:doc_083_006
- International transfersshall not transfer personal data outside the United Kingdom except where a lawful transfer mechanism is in place and the customer has been toldshall not transfer personal data outside the United Kingdom except where a lawful transfer mechanism is in place and the customer has been told · Source: object_read:doc_083_006
- Return and deletionat the customer's choice, return or delete the personal data it holds on the customer's behalf and confirm that it has done soat the customer's choice, return or delete the personal data it holds on the customer's behalf and confirm that it has done so · Source: object_read:doc_083_006
- Data locationAny change to the data location or to a dedicated residency option must be agreed in writingAny change to the data location or to a dedicated residency option must be agreed in writing · Source: object_read:doc_083_006
The document
Body
Kingdon Diagnostics - Data Processing Agreement (signed)
Status: Executed. Signed on 23 Dec 2024.
This agreement sits under the master services agreement between Kingdon Diagnostics and BB-Demo and governs the processing of personal data in connection with the company brain service.
Parties
| Role | Party |
|---|---|
| Customer, acting as data controller | Kingdon Diagnostics, Newcastle upon Tyne |
| Supplier, acting as data processor | BB-Demo, London |
Account owner at BB-Demo: Lewis Kerr. Customer success manager: Amara Obi.
Background
Kingdon Diagnostics runs diagnostic imaging services from twelve sites in the North East and Cumbria. It uses the BB-Demo service to bring referrals, reporting-turnaround tickets and invoices together for its contract managers. In doing so, BB-Demo may process personal data on the customer's behalf, including data relating to patients, referrers, staff and commercial contacts held in the customer's connected systems.
Definitions
Read the whole document (5,278 characters)
The terms controller, processor, personal data, processing, data subject and personal data breach have the meanings given in the UK data protection legislation. In this agreement the customer is the controller and BB-Demo is the processor.
Subject matter and duration
The processor processes personal data only to provide the company brain service described in the order form and the master services agreement. Processing continues for as long as the service is provided and ends when the customer's contract ends, subject to the return and deletion provisions below.
Nature and purpose of processing
- Indexing and organising data from the systems the customer chooses to connect.
- Making that data searchable and answerable through pages, chat and search for the customer's authorised users.
- Maintaining, supporting and securing the service, including logging and fault diagnosis.
Types of personal data and data subjects
The categories depend on which systems the customer connects. They may include contact details, referral and appointment references, correspondence, support ticket content and invoice records. Data subjects may include patients, referring clinicians, customer staff and contacts at trusts and insurers.
The customer is responsible for deciding which sources are connected and for keeping special category data out of scope where it is not needed for the service.
Processor obligations
The processor shall:
- process personal data only on the documented instructions of the customer, including as set out in this agreement, unless required to do otherwise by law;
- ensure that everyone authorised to process the data is bound by a duty of confidentiality;
- apply appropriate technical and organisational security measures, including access controls, encryption, separation of environments and logging;
- assist the customer, taking account of the nature of the processing, in responding to requests from data subjects;
- assist the customer with security, breach notification, impact assessments and consultation with the regulator;
- make available the information needed to show compliance and allow reasonable audits on sensible notice.
Where the data lives
The company brain is built and run inside the customer's own Snowflake account. The customer therefore keeps control of where its data is stored and who can reach it, and the processor works within that account under the access the customer grants. Any change to the data location or to a dedicated residency option must be agreed in writing.
Sub-processors
The customer gives general authorisation for the processor to use sub-processors needed to run the service. The processor shall keep a current list available to the customer, tell the customer of intended changes so that it can object, and impose the same data protection obligations on each sub-processor. The processor remains responsible for their performance.
International transfers
The processor shall not transfer personal data outside the United Kingdom except where a lawful transfer mechanism is in place and the customer has been told.
Personal data breaches
The processor shall notify the customer without undue delay after becoming aware of a personal data breach affecting the customer's data. The notice shall describe what is known about the nature of the breach, the data concerned and the steps being taken, and the processor shall cooperate with the customer's investigation.
Return and deletion
On the end of the service, the processor shall, at the customer's choice, return or delete the personal data it holds on the customer's behalf and confirm that it has done so, unless the law requires it to keep a copy.
Liability and precedence
Liability under this agreement is subject to the limits in the master services agreement. If this agreement conflicts with the master services agreement on the processing of personal data, this agreement prevails.
Signatures
Signed on 23 Dec 2024 by the authorised representatives of the parties.
| For Kingdon Diagnostics | For BB-Demo | |
|---|---|---|
| Name | Authorised signatory | Tom Ashdown |
| Title | Authorised signatory, Kingdon Diagnostics | Account Executive |
| Date | 23 Dec 2024 | 23 Dec 2024 |
Unusual terms
Current to 9 Oct 26- General authorisation for sub-processors with notice of changes
- Prevails over the master services agreement on personal data processing
- No transfers outside the United Kingdom without a lawful mechanism