Data Processing Agreement

1. Roles

The School is the Data Fiduciary: it determines the purpose and means of processing the personal data it puts into SchoolERP. We are the Data Processor, processing that data solely on the School's documented instructions.

The Subscription Agreement, these terms and the School's use of the platform's features together constitute those instructions. We will tell the School if an instruction appears to us to breach the law.

2. Subject matter and duration

Processing continues for the term of the subscription and the retention periods that follow it. Its subject matter is the administration of the School; the categories of data subject are students, their parents and guardians, and the School's teachers and staff.

3. Our obligations

• Process personal data only on the School's instructions, and never for our own purposes.
• Keep the data confidential, and bind everyone with access to the same duty.
• Apply the technical and organisational measures set out in the Security Policy.
• Enforce tenant separation so that no other school can reach the School's data.
• Assist the School in responding to a data principal's request to access, correct or erase data.
• Notify the School without undue delay on becoming aware of a personal data breach affecting it, as set out in the Breach Notification Policy.
• Delete or return the data at the end of the agreement, as the School directs.
• Make available the information the School reasonably needs to demonstrate its own compliance.

4. Sub-processors

The School authorises the sub-processors listed on the Sub-processors page. We remain responsible for their acts and omissions as if they were our own.

We will give at least thirty days' notice before adding or replacing a sub-processor. If the School reasonably objects on data-protection grounds, and we cannot offer an alternative, the School may end the subscription without penalty for the remainder of the term.

5. Platform administrator access

Our administrators may enter a School's tenancy for support. Such access is logged in the School's own audit trail with the administrator named, and every action taken while inside is attributed to that administrator rather than to the account whose view they were using.

6. International transfers

Personal data is processed in the regions listed on the Sub-processors page. We will not transfer a School's personal data to a country restricted by the Central Government under section 16 of the DPDP Act.

7. Audit

On reasonable written notice, and no more than once a year unless a breach has occurred, we will answer a School's questions about our processing and provide the evidence we hold. Where an on-site audit is genuinely necessary we will agree its scope so that it does not compromise another school's confidentiality.

8. Return and deletion

At the end of the agreement the School may export everything, as described in the Data Portability & Exit Policy. After the export window we delete the data on the schedule in the Data Retention & Deletion Policy, except where the law requires us to keep something longer.