Data Processing Agreement

Last updated January 28, 2025

Data Processing Agreement

This Data Processing Agreement (the “DPA”) forms part of, and is subject to, the Master Services Agreement (“MSA”) between ServiceChannel.com, Inc. (hereinafter “ServiceChannel”) and Customer (as defined in the MSA). Each of the Customer and ServiceChannel is referred to as a “party” and jointly as the “parties”.

WHEREAS

(i) Customer and ServiceChannel have entered into the Master Services Agreement under which ServiceChannel will provide Customer with the Services.

(ii) ServiceChannel will process Customer Data (which may contain Personal Data) in the course of providing the Services;

(iii) The parties now wish to enter into this DPA that governs ServiceChannel’s processing of such Personal Data contained in the Customer Data.

NOW, THEREFORE, the parties agree as follows:

1. Definitions:

In this Processing Agreement, terms defined in the MSA have the same meanings when used here. In addition, the following terms shall have the following meanings:

(a) “Administration Data” means: (i) contact details relating to, and the content of correspondence with the Customer’s main account holder or administrator; (ii) support enquiries submitted by the Customer’s authorized users in relation to the Service;

(b) “Affiliates” means any entity which is controlled by, controls or is in common control with ServiceChannel;

(c) “CCPA” means the California Consumer Privacy Act of 2018, Cal Civ. Code § 1798.100 et seq., including its implementing regulations and the California Privacy Rights Act of 2020;

(d) “Controller Purposes” means undertaking internal research and development to develop, test, improve and alter the functionality of ServiceChannel’s products and services; (b) creating anonymized datasets for training or evaluation of ServiceChannel’s products and services; (c) administering ServiceChannel’s relationship with the Customer under the MSA;

(e) “Customer” means the customer that has executed the Master Services Agreement;

(f) “Customer Personal Data” means, other than Ratings and Reviews, Personal Data contained in the Customer Data, as further described in Annex I to this DPA;

(g) “Data Protection Laws” means all applicable laws, rules, regulations and governmental requirements relating to the privacy, confidentiality, or security of Personal Data (as they may be amended or otherwise updated from time to time), including (without limitation) the GDPR, UK GDPR and the US Data Protection Laws;

(h) “Data Subject” means: (i) a natural person to whom Personal Data relates; and (ii) an individual that is a “data subject”, “consumer” or any equivalent term under Data Protection Laws;

(i) “GDPR” means Regulation (EU) 2016/679 (the “EU GDPR”) or, where applicable, the “UK GDPR” as defined in section 3(10) of the UK Data Protection Act 2018;

(j) “Personal Data” means any information that: (i) relates, is linked or reasonable linkable to an identified or identifiable natural person; or (ii) is otherwise “personal data”, “personal information”, “personally identifiable information” or similarly defined data or information under Data Protection Laws;

(k) “Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction (“Process”, “Processes” and “Processed” shall have the same meaning);

(l) “Ratings and Reviews” has the meaning given to it in Section 0;

(m) “Sale” or “Sell” has the meaning given to it in the CCPA;

(n) “Share” has the meaning given to it in the CCPA;

(o) “Security Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, Customer Personal Data;

(p) “Standard Contractual Clauses” means the contractual clauses annexed to the European Commission’s Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, as updated or replaced from time to time;

(q) “Sub-processor” means any outside entity engaged by ServiceChannel to process Personal Information on behalf of Customer or in order to provide the services specified in the Agreement;

(r) “UK Addendum” means the template addendum, version B.1.0 issued by the UK Information Commissioner under S119A(1) of the UK Data Protection Act 2018 and laid before the UK Parliament on 2 February 2022, as it may be revised according to Section 18 of the UK Addendum;

(s) “US Data Protection Laws” means all applicable federal and state laws rules, regulations, and governmental requirements relating to data protection, the Processing of Personal Data, privacy and/or data protection in force from time to time in the United States, including (without limitation): the CCPA, the Virginia Consumer Data Protection Act, Code of Virginia Title 59.1 Chapter 52 § 59.1-571 et seq., the Colorado Privacy Act, Colorado Revised Statute Title 6 Article 1 Part 13 § 6-1-1301 et seq., the Utah Consumer Privacy Act, Utah Code § 13-6-101 et seq., Connecticut Senate Bill 6, An Act Concerning Personal Data Privacy and Online Monitoring (as such law is chaptered and enrolled);

(t) “Usage Data” means diagnostic, usage and performance information collected by ServiceChannel in relation to the Customer’s and its authorized users’ use of the Services; and

(u) The terms “Controller”, “Processor”, “Business” and “Service Provider” have the meanings given to them in the Data Protection Laws.

2. Relationship of the parties; Compliance with law

2.1 The Customer:

(a) appoints ServiceChannel to Process the Customer Personal Data as its Processor or Service Provider;

(b) acknowledges and agrees that ServiceChannel may:

(i) use Administration Data and Usage Data for the Controller Purposes and that, for the purposes of the GDPR, it does so as a Controller.

(ii) collect and display comments, feedback and ratings submitted to ServiceChannel by the Customer’s authorized users in relation to service providers engaged by the Customer (“Ratings and Reviews“)and that, for the purposes of Data Protection Laws, it does so as a Controller or Business.

2.2 Each party shall comply with the obligations that apply to it under, and provide the same level of privacy protection as required by Data Protection Laws.

2.3 Customer shall ensure that its instructions for the Processing of Customer Personal Data comply with the Data Protection Laws. Customer shall have sole responsibility for the accuracy, quality, and legality of Customer Personal Data and the means by which Customer obtained the Customer Personal Data.

2.4 ServiceChannel shall notify Customer promptly if ServiceChannel determines that it can no longer meet its obligations under Data Protection Laws.

2.5 Customer may take reasonable and appropriate steps to:

(a) ensure that ServiceChannel uses Customer Personal Data in a manner consistent with Customer’s obligations under Data Protection Laws; and

(b) upon reasonable notice, stop and remediate unauthorized use of Customer Personal Data.

3. Processing of Customer Personal Data

3.1 ServiceChannel shall only Process Customer Personal Data on behalf of and in accordance with the MSA, this DPA and (other than any Processing for the Controller Purposes) Customer’s documented instructions. Customer instructs ServiceChannel to Process Customer Personal Data for the following purposes: (i) Processing in accordance with the MSA and any applicable orders; and (ii) Processing to comply with other reasonable instructions provided by Customer where such instructions are consistent with the terms of the MSA. ServiceChannel shall immediately inform Customer if it is unable to follow those instructions or if in its opinion, an instruction from Customer infringes Data Protection Laws.

3.2 ServiceChannel shall not:

(a) Sell or Share Customer Personal Data;

(b) retain, use, or disclose Customer Personal Data for any purpose other than for the specific business purpose of performing the Services specified in the MSA or as otherwise permitted by Data Protection Laws;

(d) combine the Customer Personal Data with Personal Data that it receives from, or on behalf of, another person or persons, or collects from its own interaction with the Data Subject, unless expressly permitted by and carried out in accordance with Data Protection Laws.

3.3. Customer warrants and undertakes that the Customer Personal Data shall not contain any of the following:

(a) Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal convictions and any other special categories of Personal Data identified in Articles 9 or 10 of the GDPR or Personal Data that is otherwise sensitive Personal Data under Applicable Data Protection Laws;

(b) biometric identifiers or templates;

(c) financial information (including, without limitation, billing information and cardholder or sensitive authentication data, as those terms are defined under the Payment Card Industry Data Security Standard);

(d) personally identifiable financial information, as defined by and subject to the Gramm-Leach-Bliley Financial Modernization Act of 1999;

(e) national identification numbers (including, without limitation, Social Security Numbers, Social Insurance Numbers, driver’s license or passport numbers or other governmentally-issued identification numbers);

(f) information relating to individuals under the age of 13;

(g) education records, as defined under the Family Educational Rights and Privacy Act of 1974;

(h) protected health information as defined by, and subject to, the Health Insurance Portability and Accountability Act.

4. Confidentiality of processing/ServiceChannel personnel

4.1 ServiceChannel shall ensure that any person it authorizes to process the Customer Personal Data (an “Authorised Person“) shall protect the Customer Personal Data in accordance with ServiceChannel’s confidentiality obligations under this Agreement.

4.2 ServiceChannel shall ensure that its personnel engaged in the Processing of Customer Personal Data are informed of the confidential nature of the Customer Personal Data and are subject to obligations of confidentiality.

4.3 ServiceChannel shall ensure that access to Customer Personal Data is limited to those personnel who require such access to perform the Services.

5. Security/Breach management and notification

5.1 ServiceChannel shall implement appropriate technical and organisational measures for the protection of the security, confidentiality and integrity of Customer Personal Data as set out in Annex II.

5.2 If ServiceChannel becomes aware of any Security Breach, ServiceChannel will promptly: (i) notify Customer of the Security Breach in accordance with the timelines required under Applicable Data Protection Laws; (ii) investigate the Security Breach and provide Customer with information about the Security Breach; and (iii) take reasonable steps to mitigate the effects and to minimize any damage resulting from the Security Breach.

5.3 ServiceChannel shall, at Customer’s request, provide Customer with reasonable assistance with Customer’s fulfilment of its obligations under Data Protection Laws in relation to a Security Breach notified to Customer by Service Channel.

5.4 ServiceChannel shall not be under any obligation to notify Customer of any unsuccessful attempts to obtain unauthorized access to Customer Personal Data or to any of ServiceChannel’s equipment or facilities storing Customer Personal Data, including, without limitation, pings and other broadcast attacks on firewalls or edge servers, port scans, unsuccessful log-on attempts, denial of service attacks, or similar incidents.

5.5. Notification(s) of Security Breaches, if any, will be delivered to one or more of Customer’s business, technical or administrative contacts by any means ServiceChannel selects, including via email. It is Customer’s sole responsibility to ensure it maintains accurate contact information on ServiceChannel’s support systems at all times.

5.6 ServiceChannel’s notification of or response to a Security Breach under this Section 5 shall not be construed as an acknowledgement by ServiceChannel of any fault or liability with respect to the Security Breach.

6. Subprocessing

6.1 Customer acknowledges and agrees that (i) ServiceChannel may appoint Affiliates as its Sub-processors; and (ii) ServiceChannel may engage third-party Sub-processors in connection with the provision of the Services. Any such Sub-processors will be permitted to obtain Customer Personal Data only to deliver the services ServiceChannel has retained them to provide, and are prohibited from using Customer Personal Data for any other purpose. ServiceChannel will enter into a written agreement that imposes upon the Sub-processor data protection obligations that are substantially similar to those imposed on ServiceChannel by this Agreement. ServiceChannel shall remain fully responsible to the Customer for the performance of the Sub-processor’s obligations under its contract with ServiceChannel.

6.2 ServiceChannel may continue to use those Sub-processors already engaged by ServiceChannel or any ServiceChannel Affiliate as at the date of this Agreement, as listed at https://bit.ly/SC_Subprocessors.

6.3 ServiceChannel shall give Customer prior written notice of the appointment of any new Sub-processor, including full details of the Processing to be undertaken by the Sub-processor. If, within 10 days of receipt of that notice, Customer notifies ServiceChannel in writing of any objections (on reasonable grounds) to the proposed appointment, ServiceChannel shall not appoint that proposed Sub-processor until reasonable steps have been taken to address the objections raised by the Customer and the Customer has been provided with a reasonable written explanation of the steps taken. Customer acknowledges that in some cases it may not be able to provide all of the Services without the use of the new Sub-processor.

7. Restricted transfers

7.1 The parties agree that when the transfer of Customer Personal Data from Customer to ServiceChannel is a Restricted Transfer it shall be subject to the appropriate Standard Contractual Clauses as follows:

(a) in relation to Customer Personal Data that is protected by the EU GDPR, the EU SCCs will apply completed as follows:

(i) Module Two will apply;

(ii) in Clause 7, the optional docking clause will apply;

(iii) in Clause 9, Option 2 will apply, and the time period for prior notice of subprocessor changes shall be as set out in Clause 6.3 of this Agreement;

(iv) in Clause 11, the optional language will not apply;

(v) in Clause 17, Option 1 will apply, and the EU SCCs will be governed by Irish law;

(vi) in Clause 18(b), disputes shall be resolved before the courts of Ireland;

(vii) Annex I of the EU SCCs shall be deemed completed with the information set out in Annex I to this Agreement;

(viii) Annex II of the EU SCCs shall be deemed completed with the information set out in Annex II to this Agreement; and

(b) in relation to Customer Personal Data that is protected by the UK GDPR, the UK Addendum will apply completed as follows:

(i) The EU SCCs, completed as set out above in clause 7.1(a) of this Agreement shall also apply to transfers of such Customer Personal Data, subject to sub-clause

(ii) below;

(ii) Tables 1 to 3 of the UK Addendum shall be deemed completed with relevant information from the EU SCCs, completed as set out above, and the options “neither party” shall be deemed checked in Table 4. The start date of the UK Addendum (as set out in Table 1) shall be the date of this Agreement; and

(c) in the event that any provision of this Agreement contradicts, directly or indirectly, the Standard Contractual Clauses, the Standard Contractual Clauses shall prevail.

7.2 In the event that the current UK Addendum or EU SCCs are superseded or replaced by new standard contractual clauses, the parties agree that such new standard contractual clauses shall automatically apply to the transfer of Customer Personal Data from the Customer to ServiceChannel and shall be deemed completed on a mutatis mutandis basis as described in Clause 7.1 above.

8. Cooperation and Data Subjects’ rights

8.1 ServiceChannel shall, to the extent legally permitted, promptly notify Customer if it receives a request from a Data Subject to exercise their rights under Data Protection Laws. ServiceChannel shall not respond to any such Data Subject request without Customer’s prior written consent except to confirm that the request relates to Customer.

8.2 To the extent Customer, in its use or receipt of the Services, does not have the ability to correct, amend, restrict, block or delete Customer Personal Data, as required by Data Protection Laws, ServiceChannel will use commercially reasonable efforts to comply with reasonable requests by Customer to facilitate such actions to the extent ServiceChannel is legally permitted to do so.

8.3 ServiceChannel shall provide reasonable cooperation to Customer (at Customer’s expense) in connection with any data protection impact assessment that may be required under Data Protection Law.

9. Termination; deletion or return of Data

9.1 This Agreement shall terminate automatically on ServiceChannel’s deletion or anonymization of all Customer Personal Data.

9.2 Upon termination or expiry of the MSA, ServiceChannel shall:

(a) if requested to do so by Customer within thirty (30) days of expiry of the MSA (the “Retention Period“) provide a copy of all Customer Personal Data in such commonly used format as requested by Customer, or provide a self-service functionality allowing Customer to download such Customer Personal Data;

(b) on expiry of the Retention Period, delete all copies of Customer Personal Data Processed by ServiceChannel or any of its Sub-processors, other than:

(i) any Administration Data or Usage Data Processed for the Controller Purposes or any Customer Personal Data which ServiceChannel is required to retain under applicable law; or

(ii) Customer Personal Data archived on back-up systems, which ServiceChannel shall securely isolate and protect from any further Processing except to the extent required by such law until deletion is possible.

10. Audit

10.1 Customer may audit ServiceChannel’s compliance with this DPA. The parties agree that all such audits shall be conducted:

(a) not more than annually, unless more frequent audits are required to comply with Data Protection Laws or required by a supervisory authority with jurisdiction over the Processing of Customer Personal Data;

(b) upon reasonable notice to ServiceChannel;

(d) in a manner that does not materially disrupt ServiceChannel’s business or operations.

10.2 With respect to any audits conducted under Section 10.1:

(a) Customer may engage a third-party auditor to conduct the audit on its behalf, save that ServiceChannel may reasonably object to the engagement of the third-party auditor if such third-party auditor is a competitor of ServiceChannel;

(b) ServiceChannel shall not be required to facilitate or assist with any audit unless and until the parties have agreed in writing the scope and timing of such audit and the reimbursement rates under Section 10.3.

10.3 Customer shall reimburse ServiceChannel for any time spent for any such audit at the rates agreed to by the parties. Before the commencement of any such audit, Customer and ServiceChannel shall mutually agree upon the scope, timing, and duration of the audit in addition to the reimbursement rate for which Customer shall be responsible. All reimbursement rates shall be reasonable, taking into account the resources expended by ServiceChannel. Customer shall promptly notify ServiceChannel with information regarding any non-compliance discovered during the course of an audit.

10.4 Customer acknowledges that ServiceChannel is regularly audited against SSAE 18 SOC 1 standard by independent third-party auditors. ServiceChannel shall supply to Customer on request, or may supply to Customer in response to any audit request, a summary copy of its audit report(s) to Customer, which shall be subject to the confidentiality provisions of the MSA. If an audit requested by Customer is addressed in the audit report provided by ServiceChannel, Customer agrees to accept such report in place of conducting a physical audit of the controls covered by the relevant report.

11. Limitation of Liability

This DPA is subject to the limitations of liability and disclaimers in the MSA.

12. Parties to this Agreement

Save as set out in the Standard Contractual Clauses, nothing in this DPA shall confer any benefits or rights on any person or entity other than the parties to this DPA.

13. Legal effect

This DPA supplements and forms part of the MSA.

14. General

14.1 This DPA shall be governed by and construed in all respects in accordance with the governing law and jurisdiction provisions in the MSA, provided that, in the event of a conflict between the MSA and this DPA with regards to the processing of Personal Data, this DPA shall control.

14.2 This Agreement may be executed in any number of counterparts, each of which is an original and all of which evidence the same agreement between the parties.

14.3 Other than as set out in this DPA, the MSA shall remain in full force and effect.

ANNEX I

A. LIST OF PARTIES

	Name	Address	Contact person’s name, position and contact details	Activities relevant to the data transferred	Role
Data exporter	Customer (as identified in the MSA)	As identified in the MSA	As identified in the MSA	Receipt of the Services	Controller
Data importer	ServiceChannel.com, Inc.	30 Patewood Dr Building 2, Suite 350, Greenville, SC 29615	Brian Chase, General Counsel, [email protected]	Provision of the Services	Processor

B. DESCRIPTION OF TRANSFER

Data subjects	Categories of personal data	Sensitive personal data	Frequency of transfer	Nature and purpose of the processing	Retention period
Customer’s authorized users	Name, email address, business address, access credentials.	None	Continuous	Granting access to the Services to Customer’s authorized users.	For as long as Customer authorizes the user to receive the Services.
Customer’s authorized users	Name, email address, phone number, business address.	None	Continuous	Facilitating contact between the Customer’s authorized user and persons contracted by the Customer through the Services (“Contractors“)	For as long as Customer authorizes the user to receive the Services.
Customer’s authorized users Contractor personnel	Facilities management services requested through the Services, date and time of request.	None	Continuous	Submission of facilities management service requests to Contractors.	For the term of the MSA.
Customer’s authorized users Contractor personnel	Name, facilities management services provided, date and location of services provided.	None	Continuous	Maintenance of records of facility management services ordered by Customer and completed.	For the term of the MSA.
Contractor personnel	Name and contact details (phone number and email address) submitted by Customer’s authorized users.	None	Continuous	Facilitating contact between the Customer’s authorized user and their key contacts at Contractors.	For the term of the MSA.
Customer’s authorized users	Support queries	None	Continuous	Providing technical support.	For the term of the MSA.
Customer’s authorized users	Log data	None	Continuous	Providing access to the Services.	For the duration of the authorized user’s browsing session.

Subprocessors

As described at https://bit.ly/SC_Subprocessors

C. COMPETENT SUPERVISORY AUTHORITY

Irish Data Protection Commissioner

ANNEX II

Security Measures

ServiceChannel will at all times remain responsible and liable for the following commercially reasonable transfer security measures:

TRANSFER SECURITY MEASURES	IMPLEMENTED MEASURES
Measures of pseudonymisation and encryption of personal data	Pseudonymization character masking swapping k-anonymity Encryption HTTPS encryption for data in transit (using TLS 1.2 or greater) on every login interface, using industry standard algorithms and certificates. Encryption of data at rest using the industry standard AES-256 algorithm
Measures for ensuring ongoing confidentiality, integrity, availabilty and resilience of processing systems and services	Confidentiality Virtual Private Network (VPN) Multi-Factor Authentication (MFA) Differentiated rights system based on security groups and access control lists. Secure transmission of credentials using TLS 1.2 (or greater) Passwords require a defined minimum complexity. Initial passwords must be changed after the first login. Automatic account locking Guidelines for handling of passwords Access controls to infrastructure that is hosted by cloud service provider Access right management including authorization concept, implementation of access restrictions, implementation of the “need-to-know” principle, managing of individual access rights. Training and confidentiality agreements for internal staff and external staff Network separation Segregation of responsibilities and duties Restrict access to personal data to the parties involved in the processing in accordance with the “need to know” principle and according to the function behind the creation of differentiated access profiles. Integrity Secure network interconnections ensured by firewalls etc. Logging of transmissions of data from IT system that stores or processes personal data Logging authentication and monitored logical system access Logging of data access including, but not limited to access, modification, entry and deletion of data Documentation of data entry rights and logging security related entries Web Application Firewall (WAF) Availability and Resilience Customer data is backed up to multiple durable data stores and replicated across multiple availability zones. Protection of stored backup media
Measures for ensuring the ability to restore the availability and access to personal Data in a timely manner in the event of a physical or technical incident	Continuity Planning and Disaster Recovery Plan Disaster recovery processes to restore data and processes Recovery Time Objective (RTO) Recovery Point Objective (RPO) Maximum Tolerable Downtime (MTD) Capacity management measures to monitor resource consumption of systems as well as planning of future resource requirements. Procedures for handling and reporting incidents (incident management) including the detection and reaction to possible security incidents. Productive data is backed up hourly in incremental form and daily as a full backup. All backups are kept redundant and in encrypted form (AES-256).
Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing	Testing of emergency equipment Documentation of interfaces and personal data fields Internal and external audits Security checks (e.g. penetration tests) conducted by external parties SOC 1 and 2 audits Regular benchmarking and testing with industry standards, e.g. SANS Top 20 Controls for Internet Security, NIST guidelines, etc.
Measures for user identification and authorisation	Secure network interconnections ensured by VPN, MFA, firewalls etc. Logging of transmissions of data from IT system that stores or processes personal data Logging authentication and monitored system access Access to data necessary for the performance of the particular task is ensured within the systems and applications by a corresponding role and authorization concept in accordance to the “need-to-know” principle. Web Application Firewall (WAF)
Measures for the protection of Data during transmission	Remote access to the network via VPN tunnel and end-to-end encryption HTTPS encryption for data in transit (using TLS 1.2 or greater)
Measures for the protection of Data during storage	System inputs recorded via log files Access Control Lists (ACL) Multi-factor Authentication (MFA)
Measures for ensuring physical security of locations at which personal Data are processed	Subdivision of the facility into individual zones with different access authorizations; Physical access protection (e.g. steel doors, windowless rooms or secured windows); Electronic access control system to protect security areas; Monitoring of the facility by security services and access logging to the facility; Video surveillance of all security-relevant security areas, such as entrances, emergency exits and server rooms; Central assignment and revocation of access authorisations; Identification of all visitors by verification of their identity card and registration (a log of visitors is kept); Mandatory identification within the security areas for all employees and visitors; Visitors must be accompanied by employees at all times.
Measures for ensuring events logging	Remote logging Hash chaining Replication Central Security Event and Information Management (SIEM) system
Measures for ensuring system configuration, including default configuration	Access Control Policy and Procedures Baseline configuration identification Configuration Planning and Management Configuration Change Management Configuration Status Accounting Configuration Verification and Audits Mobile device management
Measures for internal IT and IT security governance and management	Dedicated and identified person to oversee the company’s information security and compliance program SOC 1 and 2 audit
Measures for certification/assurance of Processes and products	Information security or quality management certifications such as SSAE 18 Type 2 SOC 1 and SSAE18 Type 2 SOC2
Measures for ensuring Data minimisation	Technological barriers to the unauthorized linking of independent sources of data. Limitation to the level of detail used in personal data processing: for example, through techniques such as k-anonymity and obfuscation. Deletion of metadata generated during certain processes that are not necessary for the pursued goal.
Measures for ensuring Data quality	Process for the exercise of data protection rights (right to amend and update information) Clear documentation of requirements for all data conditions and scenarios Restrict access to personal data to the parties involved in the processing in accordance with the “need to know” principle and according to the function behind the creation of differentiated access profiles. Rigorous data profiling and control of incoming data Data pipeline design to avoid duplicate data Quality Assurance team Enforcement of data integrity
Measures for ensuring limited data retention	The existence of clear retention schedules and policies Testing of effectiveness
Measures for ensuring accountability	Assign responsibility to ensure end-user privacy throughout the product lifecycle and through applicable business processes. Data protection impact assessments as an integral part of any new processing initiative. Document all decisions that are adopted within the organisation from a “privacy design thinking” perspective.
Measures for allowing Data portability and ensuring erasure	Documented processes in relation to the exercise by users of their privacy rights (e.g. right of erasure or right to data portability) Use of open formats such as CSV, XML or JSON.
Applied restrictions or safeguards for sensitive data (if applicable)	Encrypting or hashing special category data, although not an explicit legal requirement, should be the norm

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