Data processing agreement
Draft GDPR Article 28 agreement between each client company as controller and the TimeClockApp provider as processor.
1. Parties purpose and duration
Controller: client company. Processor: [PENDING ADVISER: provider identity]. Purpose: supply TimeClockApp under documented instructions. Duration: service term plus applicable return, restriction or deletion period.
2. Nature purpose and people
Hosting, organization, authorized changes, reporting, support, backup and deletion for timekeeping and workforce management. People include workers and authorized customer users.
3. Data categories
Work identity and contact, credentials, company and site, schedules, time records, breaks, leave, incidents, changes, reports, technical evidence and point-in-time location when enabled.
4. Instructions and confidentiality
The processor acts only on documented instructions, flags instructions it believes unlawful and limits access to authorized personnel under confidentiality.
5. Security
Access control, tenant separation, encryption in transit, password hashing, audit logs, vulnerability management, backups and recovery. The final technical annex states verified scope, frequency and responsibility.
6. Sub-processors and transfers
The approved list states provider, service, country, data and safeguard. Customers authorize sub-processing under the agreed mechanism and receive change notice with an objection period. International transfers require a valid safeguard.
7. Rights and cooperation
The processor forwards requests to the controller and assists with search, export, correction, restriction and deletion within the contractual deadline.
8. Personal data breaches
The processor notifies the controller without undue delay after awareness, including nature, categories, approximate scale, consequences, measures and contact. The internal deadline must support the controller's 72-hour assessment.
9. Assessments audits and evidence
The processor assists with risk and impact assessments and provides reasonable audit information under confidentiality and agreed conditions.
10. Return restriction and deletion
At termination the customer may export data. Data is then returned or deleted at its choice unless documented law requires restricted retention, with evidence supplied where appropriate.
11. Pending annexes
Instructions, inventory, sub-processors, transfers, technical controls, contacts, deadlines, location, assistance and return format: [PENDING LAWYER AND FINAL CONFIGURATION].