Data Processing Agreement in Accordance with Art. 28 GDPR

InLoox GmbH

Data Processing Agreement in Accordance with Art. 28 GDPR

Version: August 20, 2025

The following Data Processing Agreement (DPA) within the meaning of Art. 28 (3) GDPR governs the obligations and rights between the controller (Art. 4 (7) GDPR) of data processing - hereinafter referred to as the "controller" - and the processor (Art. 4 (8) GDPR) - hereinafter referred to as the "processor" - InLoox GmbH, Walter-Gropius-Straße 17, 80807 Munich, Germany. 

The content complies with the Commission's standard contractual clauses according to Art. 28 (6), (7) GDPR of 04.06.2021 (C 2021) 3701 final.

SECTION I

Clause 1 - Purpose and scope

a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29 (3) and (4) Regulation (EU) 2018/1725.

c) These Clauses apply to the processing of personal data as specified in Annex II.

d) Annexes I to IV are an integral part of the Clauses.

e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2 - Invariability of the Clauses

a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3 - Interpretation

a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4 - Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

SECTION II – OBLIGATIONS OF THE PARTIES

Clause 6 - Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7 - Obligations of the Parties

7.1 Instructions

a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2 Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3 Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4 Security of processing

a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5 Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6 Documentation and compliance

a) The Parties shall be able to demonstrate compliance with these Clauses.

b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7 Use of sub-processors

a) The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 14 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8 International transfers

a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8 - Assistance to the controller

a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions.

c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

1. the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a "data protection impact assessment") where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;
2. the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;
3. the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;
4. the obligations in Article 32 Regulation (EU) 2016/679.

d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required

Clause 9 - Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 Regulation (EU) 2016/679 or under Articles 34 and 35 Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

b) in obtaining the following information which, pursuant to Article 33(3) Regulation (EU) 2016/679 shall be stated in the controller’s notification, and must at least include:

1. the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
2. the likely consequences of the personal data breach;
3. the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

c) in complying, pursuant to Article 34 Regulation (EU) 2016/679 with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

b) the details of a contact point where more information concerning the personal data breach can be obtained;

c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III – FINAL PROVISIONS

Clause 10 - Non-compliance with the Clauses and termination

a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

c) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

d) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;

e) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

f) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

g) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

ANNEX I LIST OF PARTIES

Processor

Company: InLoox GmbH

Address: Walter-Gropius-Str. 17, 80807 Munich, Germany

Name, position and contact details of the contact person

Dr. Andreas Tremel (Data Protection Coordinator)

Phone: +49 89 358 99 88 0

Email: info@inloox.com

Name and contact details of the Data Protection Officer

Kemal Webersohn (WS Datenschutz GmbH)

Address: Dircksenstr. 51, 10178 Berlin, Germany

Phone: +49 30 88 72 07 88

Email: inloox@ws-datenschutz.de

ANNEX II: DESCRIPTION OF THE PROCESSING

Categories of data subjects whose personal data is processed

• Employees
• Suppliers, external service providers
• Customers
• Business partners
• Interested parties
• Other contact persons, if entered by the customer

 Categories of personal data processed

• Personal master data
• Communication data (e.g. telephone, e-mail)
• Address data
• Contract master data (contractual relationship, product or contract interest)
• Customer history
• Contract billing and payment data
• Planning and control data including resources
• Other data, if entered by the customer (e.g. date of birth, skills)

 Nature and purpose of processing

• Installation of project management software on computer systems operated by the client
• Provision of maintenance services on computer systems operated by the client
• Installation, operation and maintenance of project management software on servers of the Contractor's named subcontractor.

Duration of the processing

The duration of this contract (term) corresponds to the term of the service agreement.

ANNEX III TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA

1. Confidentiality (Art. 32 para. 1 lit. b GDPR)

• Access control (entry control / physical access control)
  A distinction is made between access control to the InLoox locations, access control to the security areas within the InLoox locations and access control to the external data centres. 
  • Access control InLoox sites:
    • Locking system (physical keys, chip cards or tokens)
    • Authorisation assignment (key management and basic access authorisations)
    • Visitor control
    • Clear desk regulations
    • Access to individual buildings or rooms by external personnel (e.g. cleaning staff) is documented
  • Access control Security areas within the InLoox sites:
    • Second, independent locking system (physical keys, fingerprint readers, chip cards or tokens)
    • Authorisation assignment (key management and basic access authorisations)
    • Restricted user group
    • General ban on visitors
  • Access control for data centres:
    A distinction is made between data centres that InLoox operates for the contractor (InLoox Cloud or Managed Services), data centres that InLoox operates for internal use (e.g. for administration, development and marketing), data centres for customer support and data centres for remote maintenance. 
    • Data centres for the operation of InLoox Cloud and for managed services:
      • InLoox does not operate its own data centres as part of InLoox Cloud and for managed services, but has rented Microsoft data centres in Germany. These data centres have various certifications, including ISO 27001.
      • The data centres are located in Frankfurt am Main and Berlin. The data is protected in accordance with German and European law.
      • Access authorisations to the data centres are personalised and restricted to a documented group of people.
      • Details on access control to the data centres can be found in Annex IV in the section "Sub-processor Microsoft Ireland Operations Limited".
      • InLoox Cloud notifies users stored in the project room of other users' actions by e-mail and special events (e.g. due date of tasks). These emails are sent via SendGrid. SendGrid is based in the United States of America, whereby the same level of protection is recognised for these data centres through standard contractual clauses. For details, see Annex IV in the section "Sub-processor SendGrid Inc.". 
    • Data centres for internal use at InLoox:
      • InLoox has rented data centres in Microsoft Azure located in the European Union. These data centres have various certifications, including ISO 27001.
      • The data centres are located in Germany and the Netherlands. The data is protected in accordance with German and European law.
      • Access authorisations to the data centres are personalised and restricted to a documented group of people.
      • Details on access control for the data centres can be found in Annex IV in the section "Sub-processor Microsoft Ireland Operations Limited". 
    • Data centres for customer support:
      • InLoox uses the Freshdesk, a software operated by Freshworks Inc. for customer support enquiries submitted by email or via a web form.
      • The use of a data centre in Frankfurt am Main,Germany, and a data processing agreement that complies with data protection regulations are contractually regulated.
      • Details on access control can be found in Annex IV in the section "Sub-processor Freshworks Inc.". 
    • Data centres for remote maintenance:
      • InLoox uses TeamViewer, a software operated by TeamViewer Germany GmbH, for remote maintenance on the customer's systems.
      • The use of a data centre in Frankfurt am Main, Germany, and a data processing agreement that complies with data protection regulations are contractually regulated.
      • Details on access control can be found in Annex IV in the section "Sub-processor TeamViewer Germany GmbH".
• Access control (authorization control / data access control)
  A distinction is made between access control to the data centres, access control to the data centres for customer support, access control to the InLoox sites, access control via the Internet and general access control.
  • General access control:
    • Access authorisations are set up according to necessity (principle of operational necessity).
    • Differentiation by department and between normal, privileged and external accounts (group and role concept).
    • Process for granting and withdrawing authorisations (documented processes for hiring/leaving authorised persons).
    • There is a policy for locking computers.
    • Timeouts are configured according to the technical possibilities.
    • The data carriers of stationary computers, laptops / notebooks and mobile data carriers are encrypted.
    • All accesses are secured with a user name and password.
    • There are requirements for password complexity.
    • Electronic and paper-based information is destroyed in accordance with data protection regulations.
  • Access control via the Internet:
    • Access to the data processing systems is generally secured with hardware firewalls.
    • Access to the data processing systems is protected by user names and passwords.
    • Access to the data processing systems is via VPN technology and personal access data.
    • Remote access to the data processing systems is only permitted to a restricted group of users.
    • Remote access to data protection-relevant systems requires two-factor authentication.
    • Data protection-relevant core systems can only be accessed via the company network.
  • Access control at the InLoox sites:
    • Access to in-house data processing systems is additionally protected using department-specific boot passwords.
    • There is a clear desk rule.
  • Access control in the data centres:
    • Remote maintenance access to the systems in the data centres is restricted to certain IP address ranges and InLoox sites (reduced access points).
    • Remote maintenance access to the systems in the data centres is reserved for special role holders (reduced user group).
    • The level of security for the data centres themselves is the responsibility of Microsoft. In addition to physical security, this also includes the security of the environment and access control guidelines. Details on the access controls for the data centres can be found in Annex IV in the section "Sub-processor Microsoft Ireland Operations Limited".
  • Access control in the data centres for customer support:
    • Remote maintenance access to systems is restricted to specific IP address ranges and InLoox sites (reduced access points).
    • Remote maintenance access to the systems in the data centres is reserved for special role holders (reduced user group).
    • The level of security for the data centres themselves is the responsibility of Freshworks. In addition to physical security, this also includes the security of the environment and access control guidelines. Details on the access controls of the data centres can be found in Annex IV in the section "Sub-processor Freshworks Inc.".
• Access control (logical access control)
  In practice, access rights are often linked to entry rights, so that the measures for entry also have indirect effects on access.
  • Access authorisations are set up according to necessity (principle of operational necessity).
  • Differentiation by department and between normal, privileged and external accounts (group and role concept).
  • Allocation and withdrawal process for authorisations (documented processes for hiring/leaving authorised persons).
  • There are requirements for password complexity.
  • Electronic and paper-based information is destroyed in compliance with data protection regulations.
• Separation control:
  • Separation of test and production systems (sandboxing).
  • Separate storage in different systems:
    • CRM / general customer data
    • ERP / accounting-relevant data
    • Service and support data
    • Productive data of InLoox Cloud customers
    • Productive data of managed services customers
  • Additional features for productive data of InLoox Cloud customers:
    • Each user account is executed on its own isolated database schema (SQL schema separation).
    • Logical client separation
    • Definition of database rights
    • Multi-level authorisation concept: different users have different rights to enter, change and delete data in the user interface.

2. Integrity (Art. 32 para. 1 lit. b GDPR)

• Disclosure control:
  • All employees are contractually bound to confidentiality and secrecy.
  • All employees are contractually bound to confidentiality under § 88 TKG ("German Telecommunications Act").
  • The data carriers of stationary computers, laptops / notebooks and mobile data carriers are encrypted.
  • Web interfaces use secure connections (TLS/SSL) with key lengths that correspond to the state of the art.
  • InLoox locations and remote connections to InLoox locations are secured via Virtual Private Network (VPN) tunnels.
  • Access to the data processing systems is generally secured with hardware firewalls.
  • The deletion periods for the data provided comply with the legal requirements and are set out in the internal deletion concept.
  • State-of-the-art encryption is used for communication with external business partners, customers and service providers if the communication partner so wishes. The signatures used for encryption are validated against the certification authority.
• Entry control:
  A distinction is made between the entry control of data that InLoox uses internally, e.g. for administration, development, support and marketing, and the entry control of productive data of InLoox Cloud customers and general entry controls.
  • General entry control:
    • Access is granted by means of individual user names and passwords.
    • A multi-level authorization concept ensures that different users have different rights to enter, change and delete data in the user interface.
  • InLoox internal entry control:
    • Versioning of internal documents (document management).
    • Versioning of source codes (source code management).
    • Logging of support tickets (customer service management).
  • Input control of productive data from InLoox Cloud customers:
    • Data records include a creation, modification and deletion flag.

3. Availability and resilience (Art. 32 para. 1 lit. b GDPR)

• Availability control:
  A distinction is made between the availability control of data that a) InLoox uses internally, e.g. for administration, development and marketing, the availability control of customer support data, the availability control of productive data of InLoox Cloud customers and the availability control of productive data of managed services customers.
  •  Availability control of internal InLoox data:
    A distinction is made between data processing systems that InLoox operates within the sites themselves and data processing systems in external data centers that InLoox has rented.
    • Data processing systems within the InLoox locations:
      • Fire protection equipment (fire extinguishers, smoke or fire detectors), no-smoking policy
      • Uninterruptible power supply (UPS)
      • Air conditioning
      • Use of RAID systems in the servers
      • Use of virus protection
      • Data backup through replication of data to various InLoox locations and external data centers.
    • Data processing systems in external data centers:
      • InLoox has rented Microsoft data centers in the European Union. These data centers have various certifications, including ISO 27001.
      • Details on the availability control of the data centers can be found in Annex IV in the section "Sub-processors Microsoft Ireland Operations Limited".
    • Availability control of customer support data:
      • Details on availability control of the data centres can be found in Annex IV in the section "Sub-processors Freshworks Inc.".
    • Availability control of productive data of customers of InLoox Cloud and for managed services
      • InLoox does not operate its own data centers as part of InLoox Cloud and for managed services, but has rented Microsoft data centers in Germany. These data centers have various certifications, including ISO 27001.
      • The data centers are located in Frankfurt am Main and Berlin. The data is protected in accordance with German and European law.
      • Simultaneous provision on independent systems ("hot spare" principle).
      • Details on the availability control of the data centers can be found in Annex IV in the section "Sub-processor Microsoft Ireland Operations Limited".
    • Additional features for productive data of InLoox Cloud customers:
      • Daily, fully automated backups of project databases. The retention period is 7 days (InLoox Professional) or 30 days (InLoox Enterprise).
      • Backup option by the customer (self-service backup)
      • Quick recovery by support staff
      • Georedundant document storage

 4. Procedures for regular review, assessment and evaluation (Art. 32 para. 1 lit. d GDPR; Art. 25 para. 1 GDPR)

• Data protection management:
  • Audit planning and implementation of internal and external audits
  • Implementation of awareness-raising measures / regular staff training
  • Reporting
  • Risk management and analysis
  • Implementation of penetration tests
  • Data protection impact assessment and action planning for new and changed processes as a standard process
• Process for handling data protection incidents:
  • Mandatory reporting / reporting processes
  • Regular staff training.
• Data protection-friendly default settings:
  • Guidelines for private end devices in company use (BYOD)
  • Guidelines for company end devices
  • Group and network security policies (domain policy)
• Order control:
  No commissioned data processing within the meaning of Art. 28 GDPR without corresponding instructions from the client through
  • Clear contract arrangement
  • Formalized order management
  • Strict selection and monitoring of the respective service provider/sub-processor

ANNEX IV: LIST OF SUB-PROCESSORS

The controller has authorised the use of the following sub-processors: