Data Processing Addendum

This addendum outlines data-processing responsibilities where Xapner processes personal data for a client under an agreed service.

When this addendum is relevant

The data processing addendum applies where XAPNER LTD processes personal data for a client while providing an agreed service. It forms part of the relevant agreement and sets out the parties’ roles, the documented instructions that govern processing and the legal framework considered for that work.

Client and Xapner responsibilities

A client normally remains responsible for deciding the lawful basis, providing privacy information and giving lawful instructions for its data. Xapner normally acts as processor only for the agreed service and documented instructions, while each party may act as an independent controller for its own contract management, billing, security or legal obligations.

Project-specific safeguards

The full addendum addresses processing details, confidentiality, security, subprocessors, incident handling, international transfers, retention and audit matters. The precise measures depend on the systems, data categories and service scope that are agreed for the individual project.

Agreement documents

The project proposal, order document and authorised instructions provide the operational detail that cannot be inferred from a public website page. A client considering a data-processing arrangement should review those documents with the complete addendum before giving Xapner access to personal data.