Data Processing Agreement (DPA)

​Data Processing Agreement
Parties

This Data Processing Agreement ("Agreement") forms part of any agreement between:

HG IP Networks Ltd ("Processor")

and

The Customer ("Controller")

where HG IP Networks processes personal data on behalf of the Customer.

 

1. Definitions

Terms such as Personal Data, Processing, Controller, Processor, Data Subject and Personal Data Breach shall have the meanings given in the UK GDPR.

 

2. Scope

HG IP Networks may process personal data when providing services including:

Telecommunications
Business connectivity
Network management
Cyber security services
Hosted voice solutions
Technical support services

 

3. Processing Activities

HG IP Networks shall:

Process personal data only on documented instructions from the Customer.
Process personal data only for the purpose of delivering contracted services.
Not use personal data for its own marketing purposes.
Comply with applicable data protection legislation.

 

4. Confidentiality

HG IP Networks shall ensure that any employees, contractors or agents with access to personal data are subject to confidentiality obligations.

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5. Security Measures

HG IP Networks shall implement appropriate technical and organisational measures, including where appropriate:

Access controls
Password management
Multi-factor authentication
Encryption in transit and at rest
Anti-malware protection
Secure backup procedures
Network security controls
Staff awareness training

 

6. Sub-Processors

The Customer acknowledges that HG IP Networks may engage approved sub-processors including but not limited to:

Telecommunications carriers
Cloud service providers
Hosting providers
Security service vendors

Sub-contractor engineers

HG IP Networks shall ensure appropriate contractual protections are in place with all sub-processors.

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7. International Transfers

Where personal data is transferred outside the UK, HG IP Networks shall ensure appropriate safeguards are implemented in accordance with applicable data protection legislation.

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8. Personal Data Breaches

HG IP Networks shall notify the Customer without undue delay after becoming aware of a personal data breach affecting Customer personal data.

Notification will include, where available:

Nature of the breach
Categories of data involved
Potential impact
Remedial actions taken

 

9. Data Subject Rights

HG IP Networks will provide reasonable assistance to enable the Customer to fulfil obligations relating to:

Subject Access Requests
Rectification requests
Erasure requests
Restriction requests
Data portability requests
Objections to processing

 

10. Return and Deletion of Data

Upon termination of services, HG IP Networks will, upon request:

Return Customer personal data; or
Securely delete Customer personal data

unless retention is required by law.

 

11. Audits

Where reasonably required, and subject to confidentiality obligations, HG IP Networks shall provide information demonstrating compliance with this Agreement.

 

12. Liability

Each party's liability under this Agreement shall be subject to the liability limitations contained within the underlying service agreement.