Whitlingham Wealth - Data Processing Agreement (signed)
Documentexecuted Whitlingham Wealth · dpa · executed · 2024-11-08
Data processing agreement dated 8 Nov 2024 between BB-Demo Limited as Processor and Whitlingham Wealth as Controller, covering personal data processed under the Master Services Agreement. It states no price, availability or response-time figures.
What it says
What this says
Current to 13 Oct 26Data processing agreement dated 8 Nov 2024 between BB-Demo Limited as Processor and Whitlingham Wealth as Controller, covering personal data processed under the Master Services Agreement. It states no price, availability or response-time figures.
What it is: a standard controller and processor DPA filed as executed under the customer's Contracts folder. It sits beneath the Master Services Agreement of the same date and covers all personal data BB-Demo processes for the Company Brain service.
Commits: BB-Demo must act only on documented instructions, and must not use the data for its own purposes without prior written consent. Personal data "shall be encrypted in transit and at rest", and subprocessors need the Controller's prior written consent.
Unusual: the term has no fixed end date. It runs for the duration of the Master Services Agreement and for as long as the Processor retains personal data.
Not settled: the signature lines in the text are blank, and the customer signatory appears only as "Authorised Signatory" with no name. The document sets no service levels, price or breach and notification timings.
As found in this document
Current to 9 Oct 26- Date signed8 Nov 2024Source: object_read:doc_182_006
- Date start8 Nov 2024Source: object_read:doc_182_006
- Processing instructionsThe Processor shall process personal data only on documented instructions from the ControllerThe Processor shall process personal data only on documented instructions from the Controller · Source: object_read:doc_182_006
- SubprocessorsThe Processor may engage subprocessors only with the Controller's prior written consent.The Processor may engage subprocessors only with the Controller's prior written consent. · Source: object_read:doc_182_006
- EncryptionPersonal data shall be encrypted in transit and at rest.Personal data shall be encrypted in transit and at rest. · Source: object_read:doc_182_006
- AccessAccess is restricted to authorised BB-Demo personnel on a need-to-know basis.Access is restricted to authorised BB-Demo personnel on a need-to-know basis. · Source: object_read:doc_182_006
- Termfor the duration of the Master Services Agreement and for such period as the Processor retains personal datafor the duration of the Master Services Agreement and for such period as the Processor retains personal data · Source: object_read:doc_182_006
The document
Body
Whitlingham Wealth, Data Processing Agreement
This Data Processing Agreement (DPA) is entered into on 8 November 2024 between BB-Demo Limited (as Processor) and Whitlingham Wealth (as Controller).
1. Scope
This DPA applies to all personal data processed by BB-Demo in the course of providing the Company Brain service under the Master Services Agreement dated 8 November 2024.
2. Processing Instructions
The Processor shall process personal data only on documented instructions from the Controller and for the purposes specified in the Master Services Agreement. The Processor shall not process data for its own purposes without the Controller's prior written consent.
3. Processor Obligations
The Processor shall:
- Implement and maintain appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and accidental loss or destruction
- Ensure that any person authorised to process personal data is subject to a duty of confidentiality
- Assist the Controller in responding to data subject requests and in meeting its obligations under data protection law
4. Subprocessors
Read the whole document (2,147 characters)
The Processor may engage subprocessors only with the Controller's prior written consent. The Processor shall ensure subprocessors are bound by equivalent data protection obligations.
5. Data Security
Personal data shall be encrypted in transit and at rest. Access is restricted to authorised BB-Demo personnel on a need-to-know basis.
6. Data Subject Rights
The Processor shall assist the Controller in enabling data subjects to exercise their rights under applicable data protection law, including rights of access, rectification, erasure and portability.
7. Term
This DPA applies for the duration of the Master Services Agreement dated 8 November 2024 and for such period as the Processor retains personal data.
Signature
For BB-Demo Limited:
Signed: ________________________
Name: Priya Raman
Title: Account Executive
Date: 8 November 2024
For Whitlingham Wealth:
Signed: ________________________
Title: Authorised Signatory
Date: 8 November 2024
Unusual terms
Current to 9 Oct 26- No fixed end date: runs while data is retained
- Subprocessors need prior written consent