Data Processing Addendum
Draft for legal review. This is the document your customers' procurement and security teams will ask for. Placeholders in [square brackets] must be completed by the operator.
1. Roles
For workspace content, you are the controller (APP entity responsible for the personal information) and we are the processor, handling it only on your instructions and to provide the service. For your own account and billing records we act as controller.
2. Subject matter and duration
Processing lasts for the term of your subscription plus the deletion grace period. Categories of data subject: your personnel, contractors, visitors, vendor contacts and any individuals named in records you enter. Categories of data: identifiers and contact details, employment and training records, health and safety incident details, and whatever else you choose to store.
3. Our obligations
- Process only on your documented instructions, and tell you if we believe an instruction is unlawful.
- Keep the security measures described in the Privacy Policy, and not weaken them during the term.
- Ensure personnel with access are bound by confidentiality and have access only as needed.
- Assist you with data subject access, correction and deletion requests.
- Notify you without undue delay on becoming aware of a personal data breach affecting your data.
- On termination, delete your data on an approved request, subject to the retained audit log and any documented legal or regulatory preservation obligation.
4. Sub-processors
Current sub-processors:
- Google Cloud Platform — hosting, database, file storage, scheduling and secret management. Region: Australia ([region]).
- Anthropic (via Google Cloud Vertex AI) — the AI features described in the Terms, served from an Australian region. Prompts are not used for model training.
- [Email delivery provider] — transactional email (invitations, verification, notifications). Region: [region].
- [Payment provider] — billing. Handles payment details; we do not store card numbers.
We will give [notice period] notice before adding or replacing a sub-processor, and you may object on reasonable data-protection grounds.
5. Systems you connect
If you connect Google Workspace or Microsoft 365, you instruct us to read the files and directory data you grant access to. Access is read-only, except for one optional, explicitly-enabled feature that creates new template files in your own Drive. We never modify or delete your existing files. Disconnecting revokes the grant and destroys the stored credential.
6. Audit and assurance
On reasonable notice, and no more than [frequency], you may request information reasonably necessary to confirm our compliance with this addendum. [Reference any certification or third-party assessment once obtained.]
7. International transfers
Primary processing is in Australia. Where a sub-processor transfers data overseas, we take reasonable steps to ensure it handles the information consistently with the Australian Privacy Principles, as required by APP 8.