Introduction:

This Data Processing Addendum (DPA) policy outlines our company’s approach to the processing of personal data by third-party vendors or partners. This policy is an important part of our data protection program, as it ensures that personal data is processed in compliance with applicable data protection regulations and that our data protection obligations are extended to third-party vendors and partners.

Scope: This policy applies to all third-party vendors and partners that process personal data on behalf of our company.

Requirements: Any third-party vendor or partner that processes personal data on behalf of our company must sign a DPA that includes the following provisions:

1. Purpose and scope of processing activities: The DPA must outline the purpose and scope of the processing activities to be carried out by the vendor or partner, including any specific categories of personal data to be processed.

2. Data security measures: The DPA must include provisions requiring the vendor or partner to implement appropriate technical and organizational measures to ensure the security of personal data, including measures to prevent unauthorized access, disclosure, alteration, or destruction.

3. Data breach notification: The DPA must require the vendor or partner to notify us without undue delay in the event of a data breach that affects personal data.

4. Data subject rights: The DPA must include provisions outlining how the vendor or partner will assist us in responding to requests from data subjects to exercise their rights under applicable data protection regulations.

5. Data transfer arrangements: The DPA must outline any restrictions on the transfer of personal data to third countries, as well as any measures to be taken to ensure that such transfers are made in compliance with applicable data protection regulations.

Approval process: All DPAs must be approved by our legal department and senior management prior to being signed by the vendor or partner.

Communication: Our company will provide a standard DPA template and guidance on how to complete it to all vendors and partners that are required to sign a DPA.

Monitoring and enforcement: We will monitor compliance with the DPA requirements and take appropriate action if a vendor or partner fails to comply. This may include termination of the vendor or partner’s access to personal data or other legal or contractual remedies.

Conclusion: By requiring all third-party vendors and partners to sign a DPA that complies with applicable data protection regulations, our company is committed to ensuring the protection of personal data and maintaining compliance with applicable laws and regulations.