⚠ TEMPLATE — NOT LEGAL ADVICE. A drafting skeleton for a GDPR art. 28 agreement between a customer (controller) and the operator (processor). It must be completed and reviewed by qualified counsel, and normally incorporates the EU Standard Contractual Clauses where data leaves the EEA. Replace every
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Data Processing Agreement
Version [1.0] · Effective [DATE] · Between [CUSTOMER] (“Controller”) and [COMPANY] (“Processor”)
1. Subject, duration, nature and purpose
The Processor processes personal data only to provide WeDraw to the Controller under the [Terms / Order Form], for the term of that agreement.
2. Categories of data and data subjects
Account data (name, email), content the Controller's users create (boards, comments), usage and security logs. Data subjects: the Controller's users and guests. [Confirm: no special-category data is expected.]
3. Processor obligations (art. 28(3))
- Process only on documented instructions; inform the Controller if an instruction infringes the law.
- Confidentiality of everyone authorised to process.
- Security measures: see Annex II and the security page.
- Sub-processors: only those listed on the sub-processor page; [N] days' notice of changes, with a right to object.
- Assistance with data-subject requests (the app's data export and account deletion), security, breach notification ([N] hours) and impact assessments.
- Deletion or return of data at the end of the service, within [N] days.
- Audits: information and [audit rights and frequency].
4. International transfers
[Data location; the transfer mechanism (EU SCCs module 2/3, UK addendum) where applicable.]
Annex I — Parties and processing
[Contact details, roles, processing details.]
Annex II — Technical and organisational measures
[Encryption, access control, row-level security per workspace, backups, logging, incident response — matching the actual deployment.]
Annex III — Sub-processors
See the sub-processor list.
Signature
[Signature blocks, or acceptance by order form / click-through as counsel advises.]