Custom contract register development for data processing agreements
Appfront builds contract registers for organisations that have many suppliers processing personal data: for each processor, the data processing agreement, which data and processing activities it covers, the sub-processors and where processing takes place, the security measures, the term, and the points at which to review or audit it, plus the link to the record of processing activities. So the data protection officer knows which supplier does what with which data, and a new sub-processor or an expired agreement doesn't go unnoticed.
What is a contract register for data processing agreements?
Under the GDPR, an organisation that has a supplier process personal data signs a data processing agreement. A municipality, school or healthcare institution quickly has dozens or hundreds: for payroll administration, cloud storage, the pupil administration system, the newsletter. Each agreement states which data is processed, for what purpose, with which security and which sub-processors. A contract register keeps track of that per processor.
In many organisations, data processing agreements sit as PDFs in a folder, sometimes in a general contract system that doesn't capture the details that matter for privacy. Which supplier processes which data, and where, isn't visible at a glance. A processor notifies a new sub-processor by email, and nobody records it. When a supplier suffers a data breach, the first step is working out which data was held there.
We build custom solutions because the register has to fit your organisation: how many processors you have, which model agreements you use, how your record of processing activities is structured, who reviews and signs agreements, and what reporting the data protection officer and management need. A general contract system tracks terms and costs; it often doesn't know which personal data and sub-processors sit behind them.
The content for each processor
Which processing activities, categories of personal data, purposes and security measures fall under each agreement.
Sub-processors and locations
The sub-processors for each processor and where data is processed, with changes recorded and assessed.
Linked to the register
Each agreement linked to the processing activities in the record of processing activities, so it's visible which processing sits with which supplier.
How we build your contract register for data processing agreements
We start with your processors: how many there are, where the agreements are kept now, and how long it took the last time you needed to find out which data was involved in an incident.
Your processors, agreements, model agreements, the record of processing activities, and who reviews and signs.
For each processor, the agreement covering processing activities, data, security, sub-processors and term.
Notifications of changes from processors, assessment, and review and audit points.
Integration with the processing register and procurement, reporting, and then ongoing management.
What a contract register for data processing agreements actually does
The components below appear in almost every register of data processing agreements. Which ones you need depends on the number of processors.
Processors
Suppliers that process personal data, with contact persons and contracts.
Agreements
Version, term, signature and the model agreement it is based on.
Data and processing activities
Which categories of personal data and which processing activities fall under the agreement.
Sub-processors
Sub-processors and processing locations, with changes and assessment.
Measures
Security measures, certifications and audit arrangements.
Review
Alerts for expiring agreements and review dates.
Who we build a processor agreement contract register for
The register is intended for organisations with many processors.
Municipalities
Many vendors for civil registry and social domain. The integration with the processing register is the core.
Healthcare providers
Health data with many suppliers. Sub-processors and measures matter most.
Schools and universities of applied sciences
Learning materials and systems with pupil data. Agreements per supplier are what is needed.
Financial services providers
Outsourcing with strict requirements. Assessment and review are the core.
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Explore OneDayBuild →Technology and integrations
This page is about data processing agreements. For cleaning up staff data, see our page on GDPR software; for contracts in general, our page on contract management software; and for risk and compliance, our page on a GRC platform. You can read about how we work under custom software development.
Why choose Appfront for your processor agreement contract register?
When a supplier suffers a data breach, every hour counts. That is what we build for: knowing which data sits where, changes that do not go unnoticed, and agreements that get reviewed.
A fast answer during an incident
You can see directly which data a processor holds and under which terms.
Sub-processors under control
A new sub-processor is recorded and assessed, not forgotten in an email.
Register and contract together
The processing register refers to the correct agreement, and vice versa.
Security and privacy for a processor agreement contract register
The register holds contracts and information about where personal data resides and how it is protected. Access is set by role: the data protection officer and lawyers manage it, while procurement and contract owners see their own suppliers.
The register runs in a European data centre or in your own environment, with encrypted storage, daily back-ups and two-factor sign-in.
Frequently asked questions about a processor agreement contract register
Questions that privacy officers and lawyers ask before getting started.
It keeps track of the data processing agreement for each processor, including the processing activities, categories of personal data, security, sub-processors and term. It records changes made by processors, flags review dates, and links the agreements to the processing register.
Under the GDPR, when an organisation has another party process personal data on its behalf. Whether someone is a processor and what the agreement must cover is something you assess with your data protection officer or lawyer.
Contract management tracks contracts in general: term, amounts, termination. This register records the content that matters for privacy: which data, which processing activities, which sub-processors and which measures.
Yes. Each processing activity in the processing register can refer to the processor and the agreement, so both records stay consistent.
A supplier notification is recorded against the agreement, with an assessment and a decision, so it is clear when and by whom it was approved.
Yes. For each agreement, we record which model it is based on and where it deviates, so that deviations stand out.
Ask this first. There are privacy management packages with a processor module, and these work well if they fit your way of working. Custom development makes sense if the register needs to align with your own contract and procurement systems, or if you have your own classification of processing activities and data.
Knowing which supplier processes which data, and under which arrangements?
Tell us how many processors you have, where the agreements are currently kept and how your processing register is structured. We'll show you what the register, the sub-processors and the integration would look like.