UK GDPR processing terms for CoreCare customers.

Parties. The customer identified in the applicable order is the “Controller”. Christopher Anthony Warman, trading as CoreCare Systems, a sole trader operating from Red Lion, Fen Road, East Kirkby, Spilsby, PE23 4DB, United Kingdom, is the “Processor”. The ICO application reference is C1999522; a public registration number will be stated only after publication on the ICO register. The order, customer terms and this DPA form the agreement.

1. Scope and priority

This DPA applies only to processing of personal data by CoreCare on the Controller’s behalf in providing the ordered CoreCare products, support, hosting, onboarding, export and deletion services. If this DPA conflicts with the customer terms on data protection, this DPA takes priority.

2. Definitions

“Data Protection Law” means the UK GDPR, the Data Protection Act 2018 and binding legislation that replaces or supplements them. “Controller”, “Processor”, “Data Subject”, “Personal Data”, “Personal Data Breach”, “Processing” and “Supervisory Authority” have the meanings given by Data Protection Law. “Subprocessor” means another processor engaged by CoreCare.

3. Documented instructions

CoreCare will process Customer Personal Data only on the Controller’s documented instructions, including the agreement, configured product use, authorised support requests and written instructions accepted by CoreCare. CoreCare will tell the Controller if an instruction appears to infringe Data Protection Law, unless law prohibits that notice. CoreCare will process data beyond those instructions only where required by applicable law and, unless prohibited, will tell the Controller before doing so.

4. Confidentiality and access

CoreCare will ensure that people authorised to process Customer Personal Data are subject to an appropriate duty of confidentiality, receive access only where needed for their role and are informed of relevant data protection responsibilities. Customer administrators remain responsible for user permissions, lawful use and removing access that is no longer needed.

5. Security

CoreCare will implement appropriate technical and organisational measures having regard to the state of the art, implementation cost, the nature, scope, context and purposes of processing, and risks to people. The current baseline includes encrypted network transport, provider-managed encryption at rest for hosted databases and object storage, server-side access and tenant checks, product-owned credential and session controls, secure session cookies, website rate limiting, security headers, operational monitoring, audit records, restricted support access, recovery facilities and incident handling. Product-specific password, MFA, recovery, restore-test and assurance measures are recorded in the order or security schedule and must not be assumed from this baseline.

6. Subprocessors

The Controller gives general written authorisation for the subprocessors listed on the CoreCare subprocessor page. CoreCare will impose materially equivalent data protection obligations on each Subprocessor, remain responsible for its processor obligations, and provide notice of an intended addition or replacement so the Controller can raise a reasonable data-protection objection. If the parties cannot resolve an objection, either may end the affected service on written notice.

7. International transfers

CoreCare will not make a restricted transfer of Customer Personal Data without a lawful transfer mechanism and any supplementary measures required by Data Protection Law. On request, CoreCare will identify the relevant mechanism for an authorised Subprocessor. The Controller is responsible for its own transfers into and out of the service.

8. Data subject rights

Taking account of the nature of the processing, CoreCare will provide reasonable technical and organisational assistance for the Controller to respond to requests concerning access, correction, erasure, restriction, portability, objection or automated decision-making. If CoreCare receives a request that concerns Customer Personal Data, it will direct the requester to the Controller where appropriate and notify the Controller, unless prohibited by law. CoreCare will not respond on the Controller’s behalf without authorisation.

9. Breaches and compliance assistance

CoreCare will notify the Controller without undue delay after becoming aware of a Personal Data Breach affecting Customer Personal Data. The notice will provide available information about the nature and likely consequences, affected data and people, containment or mitigation, and a contact point; information may be supplied in phases. CoreCare will reasonably assist with security, breach assessment and notification, data protection impact assessments and prior consultation, taking account of the processing and information available to CoreCare.

10. Records, audits and evidence

CoreCare will maintain records required of a Processor and make information reasonably necessary to demonstrate compliance with this DPA available to the Controller. No more than once each year, unless a breach or regulator reasonably requires more, the Controller may request relevant documentary evidence and an audit by an independent qualified auditor. Audits must protect other customers, confidential information and system security, occur on reasonable notice during business hours, and avoid unnecessary disruption. The Controller bears its audit costs unless the audit identifies a material CoreCare breach.

11. Return and deletion

During the service, the Controller may use available export functions or request a reasonable export. At the end of the affected service, CoreCare will, at the Controller’s choice, return or delete Customer Personal Data after the agreed retrieval period, and delete copies, unless applicable law requires retention. Deletion from active systems and expiry of protected recovery copies may occur on different schedules. Legal holds suspend deletion only for the affected records and are documented.

12. Controller responsibilities

The Controller confirms that its instructions and use have a lawful basis, that required notices are given, that special-category or criminal-offence data is used only where lawful and agreed, and that its users collect and disclose only necessary information. The Controller will configure retention and permissions, handle requests for its records, notify CoreCare promptly of relevant concerns, and not use demonstration environments for live sensitive information unless expressly approved.

Schedule 1 — processing details

Schedule 2 — contact and variations

Operational privacy notices and requests may be sent to privacy@corecaresystems.co.uk. A change to this DPA that materially reduces protection will not apply during a current paid term without the Controller’s agreement, except where required by law.