Data processing
Data processing summary
The processing terms behind a licence, written so a security or procurement team can review them without a call: roles, obligations, subprocessors, breach notification and deletion.
Last updated November 2026
What this page is
This is a plain-language summary of the data processing terms that apply when your organization buys a licence. It exists so your procurement, legal and security teams can review the arrangement before a signature is needed. The countersigned agreement itself is provided on request and prevails over this summary if the two differ.
Roles
Your organization is the controller: you decide who is trained, what the deadline is, and what you do with the results. We are the processor: we run the training and reporting on your instructions, and we do not use your people’s records for our own purposes.
Scope and purpose of processing
- Creating and maintaining accounts for the people you invite or who sign up on your licensed domain.
- Delivering the study material, recording progress, scoring the knowledge test and issuing certificates.
- Reporting completion and scores back to the manager named on the licence.
- Sending the service emails the arrangement requires: invites, reminders, receipts, certificates and licence notices.
- Handling payment for the licence. We do not process employee data for advertising or profiling.
Our obligations
- Process personal data only on your documented instructions, and only for the training and reporting described above.
- Keep the people with access to your records to those who need it, bound by confidentiality.
- Apply the technical and organizational measures described on the trust page: TLS in transit, encryption at rest, server-side licence checks and scoped access for managers.
- Assist you with requests from your employees to access, correct or delete their records.
- Notify you without undue delay, and within 72 hours of confirming a breach, of any personal data breach affecting your records, with what we know and what we are doing.
- Return or delete your records at the end of the agreement, at your choice, subject to any legal retention obligation.
Subprocessors
We use a small set of subprocessors for hosting, database storage, email delivery and card payments. They are bound by terms at least as protective as these, and the current list is published on the trust page. We tell you before adding one that will process your people’s personal data, and you may object.
International transfers
Records are stored in the region our hosting provider operates for this application. Where a subprocessor processes data outside your region, the transfer relies on the standard contractual clauses or an equivalent safeguard offered by that provider.
Employee requests
A person can see their own progress and certificate, and can ask their manager or us to correct a name or email address. Deletion requests are honored unless a retention obligation applies: a certificate already issued and relied on for compliance may be retained for verification, while the person is hidden from reporting.
Security incidents
If we become aware of an incident affecting your records, we confirm its scope, tell your named contact what happened and what data was involved, and set out the containment steps taken. We do not wait for a full root-cause report to notify you, and we do not discuss an incident publicly in a way that identifies your organization without your agreement.
Audit and assurance
We answer security questionnaires and provide our current hosting and payment-provider assurance documentation to your security team. On-site audits are by agreement, with reasonable notice and confidentiality, and no more than once a year unless an incident requires more.
Term and termination
The processing terms run for as long as the licence is active. When it ends, you have the period stated in your order to export your records, after which they are deleted. Reporting can be exported as a CSV at any time from the manager’s team page, so you are never locked out of your own completion record.
Getting the signed agreement
Ask for the countersigned data processing agreement from the address your organization used to buy the licence, and tell us the legal entity name and signatory. We return a signed copy, and we can work from your own paper if your procurement team requires it.